Colorado State Board of Education v. Adams County School District 14.

2023 CO 52. No. 23SC61. Standing—Political Subdivision Doctrine—Local Government Law.

October 16, 2023

The Supreme Court abandoned the judicially created political subdivision doctrine in Colorado and its articulation in Martin v. District Court, 550 P.2d 864 (Colo. 1976) (the “rule of Martin”), and held that state agencies, political subdivisions, and their officials no longer need to comply with an additional, specialized test to establish standing to bring suit. Instead, Wimberly v. Ettenberg, 550 P.2d 535, 539 (Colo. 1977), supplies the sole test for determining whether a party has standing in Colorado. Applied to the facts of this case, the Court held that Adams County School District 14 (Adams 14) failed to assert an injury in fact to a legally protected interest.

Accordingly, the Court affirmed the district court’s order dismissing each of Adams 14’s claims for lack of standing.