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Colorado Revised Statutes

Colo. Rev. Stat. § 1-45-113 (2026)

Sanctions

✓ current as of July 2026
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(Repealed)

Source: Initiated 96: Entire article R&RE, effective upon proclamation of the Governor, January 15, 1997. L. 98: (6) added, p. 633, § 3, effective May 6; (6) added, p. 952, § 4, effective May 27. L. 2000: (1), (2), (3), and (4) amended, p. 127, § 9, effective March 15. L. 2001: (4) amended, p. 1110, § 1, effective September 1. Initiated 2002: Entire section repealed, effective upon proclamation of the Governor (see editor's note, (2)).

Editor's note: (1) This section was similar to former § 1-45-121 as it existed prior to 1996. (2) (a) Subsection (4) of section 1 of article V of the state constitution provides that initiated and referred measures shall take effect from and after the official declaration of the vote thereon by the proclamation of the Governor. The measure enacting article XXVIII of the state constitution takes effect upon proclamation of the vote by the Governor. The Governor's proclamation was issued on December 20, 2002. However, section 13 of the measure enacting article XXVIII of the state constitution provides that the effective date of article XXVIII is December 6, 2002. (b) This section was repealed by an initiated measure that was adopted by the people in the general election held November 5, 2002. Section 12 of article XXVIII provides for the repeal of this section. For the text of the initiative and the vote count, see Session Laws of Colorado 2003, p. 3609.

Notes of Decisions
Cited in 14 cases, 1988–2020 · leading case: Kourlis v. Dist. Court, El Paso Cnty., 930 P.2d 1329 (Colo. 1997).
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Kourlis v. Dist. Court, El Paso Cnty., 930 P.2d 1329 (Colo. 1997). · cites it 8× “Furthermore, although no cases have interpreted it as such, an additional example of a statute that may be viewed as providing mandatory injunctive relief in the face of an administrative violation is section 1-45-113(2)(a), 1B C.R.S. (1996 Supp.”
Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988). · cites it 4× “Although the Secretary of State is charged with the administration and enforcement of the Campaign Reform Act, § 1-45-113, IB C.R.S. (1980 and 1987 Supp.”
Common Sense All. v. Davidson, 995 P.2d 748 (Colo. 2000). · cites it 4× “See § 1-45-113(1), 1 C.R.S. (1999). In addition to other sanctions, the violator is liable for double the amount contributed or received in violation of the statute.”
Davidson v. Comm. for Gail Schoettler, Inc., 24 P.3d 621 (Colo. 2001). · cites it 2× “The ALJ issued her order over two and one-half years ago.”
Colorado Common Cause v. Coffman, 85 P.3d 551 (Colo. Ct. App. 2004). · cites it 4× “However, read in context, the term “contribution limits” as used in § 1-45-113 included, as relevant here, the statutory restrictions on the expenditure of public money.”
League of Women Voters of Colorado v. Davidson, 23 P.3d 1266 (Colo. Ct. App. 2001). · cites it 3× “Section 1-45-113(2), C.R.S$.2000. The Act also provides daily penalties for failure to file timely reports of contributions and expenditures.”
Sherritt v. Rocky Mountain Fire Dist., 205 P.3d 544 (Colo. Ct. App. 2009). · cites it 6× “When the ALJ’s order was issued on April 1, 2008, section 1-45-117(4) provided, in pertinent part: Any violation of this section shall be subject to the sanctions authorized in section 1-45-113 or any appropriate order or relief, including injunctive relief or a restraining…”
v. Colorado Dep't of Pub. Health & Env't, 2020 COA 50 (Colo. Ct. App. 2020). · cites it 3× “1995) (holding that the statutory injunction standard in section 1-45-113(2)(c), C.R.S. 1994, of the Campaign Reform Act, which mandated injunctions against violators of the act, controlled over C.”
Denver Area Labor Fed'n, AFL-CIO v. Meyer, 907 P.2d 638 (Colo. Ct. App. 1995). · cites it 4× “See § 1-45-113, C.R.S. (1994 Cum.Supp.); Ace West Trucking, Inc.”
Larimer Cnty. Commissioners v. Sec'y of State, 911 P.2d 698 (Colo. Ct. App. 1995). · cites it 7× “Section 1-45-113, C.R.S. (1980 Repl.Vol. IB).”
Coffman v. Colorado Common Cause, 102 P.3d 999 (Colo. 2004). “" § 1-45-113(2), 1 C.R.S. (2002). While it is arguable that these penalties were reserved for violations of section 1-45-105.”
Denver Area Labor Fed'n, AFL-CIO v. Buckley, 924 P.2d 524 (Colo. 1996). · cites it 2× “On December 15, 1992, the petitioners filed a verified complaint with the Secretary pursuant to section 1-45-113(2) of the Act alleging that the Authority, as a political subdivision of the state, violated the Act and exceeded its statutory authority in making these…”
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— Colo. Rev. Stat. § 1-45-113(1) — 2 cases
Common Sense All. v. Davidson, 995 P.2d 748 (Colo. 2000). “See § 1-45-113(1), 1 C.R.S. (1999). In addition to other sanctions, the violator is liable for double the amount contributed or received in violation of the statute.”
Colorado Common Cause v. Coffman, 85 P.3d 551 (Colo. Ct. App. 2004). “However, read in context, the term “contribution limits” as used in § 1-45-113 included, as relevant here, the statutory restrictions on the expenditure of public money.”
— Colo. Rev. Stat. § 1-45-113(2) — 8 cases
Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988). “Although the Secretary of State is charged with the administration and enforcement of the Campaign Reform Act, § 1-45-113, IB C.R.S. (1980 and 1987 Supp.”
Davidson v. Comm. for Gail Schoettler, Inc., 24 P.3d 621 (Colo. 2001). “The ALJ issued her order over two and one-half years ago.”
League of Women Voters of Colorado v. Davidson, 23 P.3d 1266 (Colo. Ct. App. 2001). “Section 1-45-113(2), C.R.S$.2000. The Act also provides daily penalties for failure to file timely reports of contributions and expenditures.”
Common Sense All. v. Davidson, 995 P.2d 748 (Colo. 2000). “See § 1-45-113(1), 1 C.R.S. (1999). In addition to other sanctions, the violator is liable for double the amount contributed or received in violation of the statute.”
Coffman v. Colorado Common Cause, 102 P.3d 999 (Colo. 2004). “" § 1-45-113(2), 1 C.R.S. (2002). While it is arguable that these penalties were reserved for violations of section 1-45-105.”
— Colo. Rev. Stat. § 1-45-113(2)(a) — 1 case
Kourlis v. Dist. Court, El Paso Cnty., 930 P.2d 1329 (Colo. 1997). “Furthermore, although no cases have interpreted it as such, an additional example of a statute that may be viewed as providing mandatory injunctive relief in the face of an administrative violation is section 1-45-113(2)(a), 1B C.R.S. (1996 Supp.”
— Colo. Rev. Stat. § 1-45-113(2)(c) — 2 cases
v. Colorado Dep't of Pub. Health & Env't, 2020 COA 50 (Colo. Ct. App. 2020). “1995) (holding that the statutory injunction standard in section 1-45-113(2)(c), C.R.S. 1994, of the Campaign Reform Act, which mandated injunctions against violators of the act, controlled over C.”
State ex rel. Meyer v. Ranum High Sch., 895 P.2d 1144 (Colo. Ct. App. 1995).
— Colo. Rev. Stat. § 1-45-113(4) — 1 case
Citizens for Responsible Gov't State Political Action Comm. v. Davidson, 236 F.3d 1174 (10th Cir. 2000).
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