## Facts

- Petitioners owning small parcels of unimproved land sought to organize the Academy Park Metropolitan District, a special district covering about 230 acres within the City of Lakewood.
- Opponents owned developed commercial property within the proposed district and objected to inclusion of their properties.
- The petition proceeded under Colorado’s Special District Act, which sets petition requirements, allows exclusion requests, and provides for later voter approval through district elections.
- The Lakewood City Council published notice and held a public hearing, then adopted a resolution approving organization of the district.
- Opponents sued the City, the City Council, and petitioners, seeking (1) C.R.C.P. 106(a)(4) review, (2) invalidation of portions of the Act as an unconstitutional delegation and as violating due process, and (3) declaratory relief challenging the Act’s election provisions.
- The district court dismissed the Rule 106(a)(4) claim as not reviewable (quasi-legislative action), rejected the constitutional claims, and dismissed the election challenge as premature.

## Issues

1. Whether the City Council’s approval of the petition to organize a metropolitan district was quasi-judicial (reviewable under C.R.C.P. 106(a)(4)) or quasi-legislative (not reviewable under that rule).
2. Whether the Special District Act unconstitutionally delegated legislative power by leaving local approval without adequate statutory standards.
3. Whether the Act and the approval process violated procedural or substantive due process rights of objecting landowners.
4. Whether a declaratory challenge to the Act’s future election procedures was ripe for adjudication.

## Decision

- The Colorado Supreme Court affirmed the district court.
- The City Council’s approval was quasi-legislative, so dismissal of the C.R.C.P. 106(a)(4) claim was proper.
- The Special District Act did not constitute an unconstitutional delegation of legislative power.
- The Act and the approval process did not violate procedural or substantive due process.
- The declaratory challenge to election procedures was unripe and properly dismissed as premature.

## Legal Principles

- C.R.C.P. 106(a)(4) review applies to quasi-judicial governmental actions; quasi-legislative decisions are not reviewable under that mechanism.
- The presence of notice and a hearing does not, by itself, convert a legislative-type policy decision into a quasi-judicial adjudication.
- Legislative delegations are permissible when the statutory scheme supplies a meaningful framework of objectives, procedures, and constraints, even if local bodies retain discretion in applying the scheme.
- For legislative-type governmental actions, due process generally does not require individualized notice or trial-like adversarial procedures.
- Substantive due process challenges to governmental-structure and economic regulation are evaluated under a deferential rational-basis standard.
- Declaratory relief requires a concrete and immediate controversy; challenges to future election procedures may be dismissed as unripe when the alleged injury depends on contingent future events.

## Conclusion

The court treated municipal approval of a metropolitan district petition as a policy decision rather than an adjudication, foreclosing Rule 106(a)(4) review, upheld the Special District Act against delegation and due process attacks, and declined to decide speculative challenges to election procedures before any election occurred.


State Farm Mut. Auto. Ins. Co. v. City of Lakewood, 788 P.2d 808 (Colo. 1990)