Northern Integrated Supply Project Water Activity Enterprise v. VIMA Partners, LLC.

2026 CO 29. No. 25SA305. Eminent Domain—Water Activity—Statutory Interpretation.

May 4, 2026

In this C.A.R. 21 proceeding brought by a private landowner, the supreme court issued an order to show cause to consider whether a water activity enterprise formed under CRS §§ 37-45.1-101 to -107 has the authority to bring an eminent domain proceeding against a private property owner.

The court concluded that pursuant to the express terms of § 37-45.1-103(4) and § 37-45-118(1)(c), a water activity enterprise has the power to condemn private property in relation to water activities. Further, on the facts presented here, the court concluded that Northern Integrated Supply Project Water Activity Enterprise had the authority to condemn easements on private land owned by VIMA Partners to survey, locate, construct, operate, and maintain pipelines and related infrastructure for its water delivery project because that work related to water activities as defined by statute.

Accordingly, the court discharged the order to show cause and remanded this case to the district court for further proceedings.