Colorado LegiSource

An informational and educational resource for the Colorado General Assembly by the Office of Legislative Legal Services.

Month: April 2021

  • How Federalism Shapes the People’s Courts

    by Jessica Wigent

    Editor’s note: This article was originally posted December 31, 2015. Because the impact of federalism on our judicial system is still relevant, we decided it would be helpful to post it again.

    In a recent webcast presented by the Council of State Governments, Lisa Soronen, executive director of the State and Local Legal Center, and Paul Clement, a former U.S. Solicitor General, discussed federalism, how it guides our complex judicial system, and how courts’ decisions impact state governments. It’s a useful review as we come to the close of 2015 and look ahead to court cases in the coming year.

    Federalism, from the Latin root foedus, or “formal agreement or covenant,” is a system of government where authority is allocated between national and state governments— and for our purposes here, state and federal courts.

    Alexander Hamilton, “the ten dollar founding father without a father,” as he is described in the celebrated Broadway play named for him, summed up the usefulness of our system, calling it “a double security to the people,” because if our rights “are invaded by either [our state or federal government], [we] can make use of the other as the instrument of redress.”

    So how does this intricate balance of power work?

    The federal courts:

    • Answer constitutional questions (Was a fundamental liberty at stake in the gay marriage debate? The Supreme Court said yes in Obergefell v. Hodges)
    • Handle interstate tussles (The Supreme Court is currently deciding whether to hear Oklahoma’s and Nebraska’s lawsuit against Colorado over recreational marijuana)
    • Step in when Congress passes a law some say is murky (What did Congress really mean to say about subsidies and federal and state health exchanges in the Affordable Care Act? The Supreme Court answered this question in King v. Burwell)
    • Hear cases where the United States is suing or being sued (Remember when then-President Richard Nixon tried to tell the New York Times and the Washington Post they couldn’t publish the then-classified Pentagon Papers? In New York Times Co. v. United States, the Supreme Court said the First Amendment protected the paper’s right to publish the documents detailing the country’s involvement in Vietnam)

    And the state courts? Well, they decide (almost all of) the rest—from traffic tickets to whether awarding state-funded tuition scholarships to students who attend sectarian schools violates the Colorado Constitution. (Whether the latter violates the First Amendment of the U.S. Constitution is an issue the federal courts would have to decide.)

    The structures of the federal and state courts are fairly similar:

    Level Colorado State Level Courts Federal Level
    Lower courts (hold trials, make findings of fact and law) County and district courts, scattered throughout 22 judicial districts across the state, and specialized courts (like our seven water courts) U.S. District Court, District of Colorado
    Intermediate courts (hear appeals from the lower courts) Colorado Court of Appeals 10th Circuit Court of Appeals
    The high court (hears appeals from the intermediate courts, sometimes) Colorado Supreme Court U.S. Supreme Court

    So we’ve got the levels down; we know which cases end up in which court. Now, how do cases get decided?

    Again, both state and federal courts work similarly. As Soronen explained, the courts use a hierarchy of laws when making their decisions. First, they look to the (federal and/or state) constitution, then to statutes passed by the Congress/legislature, then to rules and regulations created by administrative agencies (like the I.R.S. or the Colorado Department of Education), and, finally, they look to case law and common law.

    The law develops through the expansion of case law—as courts answer more and more questions and make rulings on certain issues, they have more and more references to turn to and follow when considering their decisions. This is called applying precedent—or stare decisis, meaning Let it Stand!—and it is (usually) the guiding principle of our judicial system, aiding both we the people and the courts in many ways:

    • It’s efficient
    • It’s fair
    • It gives the system predictability
    • It’s a check on arbitrary behavior

    So when does precedent apply? Lest you think we forgot the title of this post (we are supposed to be talking about federalism after all) the precedent of a state court applies just to that state’s courts. If the Colorado Supreme Court says it tastes like chicken, so do the Colorado Court of Appeals and the county and district courts. But whatever it tastes like in California or New Jersey or Texas doesn’t affect what it tastes like in Colorado. In the federal system, the same hierarchy applies within the districts and circuits, except that, when the U.S. Supreme Court says it tastes like chicken, every court in our fair land—state and federal— says it does too.

    Soronen explained that state courts are not bound by interpretations of federal law made by the federal district courts or federal courts of appeals, even in the same state! And this means? Judges in state courts throughout Colorado aren’t bound by rulings made by a judge from the U.S. District Court, District of Colorado or the Tenth Circuit Court of Appeals. This can get confusing fun (States interpret state and federal law! Federal courts can’t tell state courts what to do!) and is a product of the philosophical compromise of our Founding Fathers that led to our federalist system of government.

    We Coloradans would do well to understand how federalism and the courts work, so we can better understand why TABOR has been challenged in both state and federal courts, why our friendly state neighbors to the east and southeast are suing us over marijuana in federal and not state court, and why, at least for now, our school voucher cases have only been heard in state court.

    At the Constitutional Convention in 1787, Delaware Delegate John Dickinson famously said: “Let our government be like that of the solar system. Let the general government be like the sun and the states the planets, repelled yet attracted, and the whole moving regularly and harmoniously in several orbits.” What we ended up with is more complicated than what he envisioned, but it’s a system, and it’s ours.

  • Throwback Thursday: Looking Back at 1921 and the Twenty-third General Assembly – Part 2

    Throwback Thursday: Looking Back at 1921 and the Twenty-third General Assembly – Part 2

    by Patti Dahlberg

    In the first part of our look back at 1921 and the Twenty-third General Assembly, we learned that the “Roaring Twenties” we associate with economic prosperity and freewheeling social spirit started out with America struggling with a faltering economy and growing social unrest. By the time the General Assembly was gaveled into order the first week of January 1921, the Dow Jones had been spiraling downward for 12 months, the nation had suffered the worst terrorist attack in its history, and Colorado’s rural economy was faltering.

    The General Assembly convened at “12 o’clock, noon” on Wednesday, January 5, 1921. At the time, the Colorado Constitution required the legislature to convene on the first Wednesday in January. In the House of Representatives, Mr. R.L. Shaw, the acting Chief Clerk of the House of the twenty-second General Assembly, called the House to order and read the official announcement from the Secretary of State’s office designating the members elected to the House. Mr. Shaw was then elected as temporary Chief Clerk (later elected the permanent Chief Clerk) for the twenty-third General Assembly and roll was called. Representative Godsman was unanimously elected as temporary speaker and escorted to the podium to make a few remarks. A committee on credentials was selected to certify the Secretary of State’s list of elected members, and another committee was appointed to inform the Supreme Court that the members of the House were ready to receive their oath of office. After the oath was administered, Representative Roy A. Davis of El Paso County was elected to preside as Speaker of the House and took the oath of office. (Photo from Presidents and Speakers of the Colorado General Assembly, Denver, Colorado, 2016 Edition.)  The 1921 House convening day session ended by adjourning in memory of Charles A. Raye, former Representative from Las Animas County.

    Down the hall, the Senate was called to order by Lieutenant Governor George Stephan, presiding as the Senate President. (Before 1974, the constitution required the state’s Lt. Governor to serve as President of the Senate, voting only when needed to break a tie.) Roll for the holdover Senators was called, and the Senate President appointed several temporary staff members, including Mr. N.N McLean as temporary Secretary of the Senate (later elected the permanent Secretary). The Senate Secretary read the Secretary of State’s official announcement designating the newly elected Senators. A committee on credentials was selected to certify the Secretary of State’s list of elected members, and another committee was appointed to inform the Supreme Court that the newly elected Senators were ready to receive their oath of office. After the oath was administered, the new roll was called. The next order of business was election of a President pro tem of the Senate. Francis J. Knauss was elected with 24 votes and escorted before the bar of the Senate to receive the oath of office. Several days later, on Tuesday, January 11 (the 7th Legislative Day), a joint session was convened to introduce and administer oaths of office to the re-elected Governor Shoup and the newly elected Lt. Governor Earl Cooley, as well as other elected state officials. Lt. Governor Cooley was then presented with the Senate gavel to begin his duties as Senate president. (Photo from Presidents and Speakers of the Colorado General Assembly, Denver, Colorado, 2016 Edition.) 

    On the third legislative day, Friday, January 7, 1921, the honorable Oliver H. Shoup, 22nd Governor of Colorado, addressed a joint session of the House of Representatives and the Senate. He began his address with “Great responsibility at all times rests on those charged with the duty of making and enforcing laws, and it is not an exaggeration to say that this responsibility rests heavy at this time both in State and Nation. The situation is hopeful rather than alarming, but must engage our most serious thought and consideration.” The state and national economy was suffering, and quoting from a recently attended Governor’s conference, he said, “The financial situation in the whole country is cause for the gravest concern but not for despair. All lines of business are realizing heavy losses, but the swift decline of prices of farm commodities to far below the cost of production threatens a national disaster. The situation demands infinite patience and forbearance and supreme wisdom and courage. Nothing but evil can result from anger or fear.”  He made a public appeal for individuals and communities to do all they could to help their neighbors and neighborhood businesses, and “to not destroy” good people because they cannot immediately meet obligations. He encouraged the General Assembly to legislate what relief it could to assist the people of Colorado, in particular farmers and stock growers who were especially hard hit.

    Governor Shoup outlined legislative actions that he considered most important.  He asked for highway legislation for the state to construct and maintain public roads and highways, and to assign highway oversight responsibility to a state official who would report directly to him. He encouraged the Legislature to introduce a series of bills to consolidate state departments to eliminate work duplication. The Governor indicated that a new code was needed to systematize the state’s administrative work and asked the General Assembly to “submit to the people a proposal for a constitutional convention” to make the necessary changes to the state’s constitution. He proposed that the state’s budget process allow for more input from the Governor’s office and state departments and that the State Auditing Board be abolished in favor of a Central Purchasing Agency.

    Other concerns were the disparity in teacher salaries across the state, term limits for public officials, protecting investors from the sale of worthless securities, job training and vocational education, and the need for more child welfare laws and for better laws to protect Colorado’s game and fish. He applauded the National Guard for its assistance in monitoring domestic disturbances and protecting life and property during the Tramway strike and asked for an appropriation to construct National Guard armories. He announced the revival of the Colorado Rangers (established in 1861, they served as the State’s first statewide law enforcement agency) and asked the legislature to appropriate the necessary funds for it. The Governor recommended an increase in the state’s low inheritance tax and suggested that state revenue could also be increased by gathering more accurate property information. He called for the legislature to appropriate money for higher education to help cover expenses until the mill levy money recently approved by voters would become available in 1922.

    The members of the Twenty-third General Assembly introduced 632 House bills and 468 Senate bills, enacting 252 of them. During its 91 days of session that year, the General Assembly passed several bills appropriating money for the Agricultural College and its various satellite stations, the Fort Lewis School, Colorado School of Mines, University of Colorado, University of Colorado Medical School, and the State Teachers College of Colorado. Other bills passed included a bill appropriating money for constructing armories for the National Guard or other military forces in Colorado and a bill relating to the National Guard of Colorado, which named the Governor as the Commander in Chief except when the guard was acting on behalf of the Federal Government. The legislature also passed bills that divided the State into four congressional districts, prohibited the practice of clairvoyancy, updated inheritance tax laws, equalized teacher salaries, required the teaching of Colorado history and civil government in public schools, and changed the name of the Grand River to the Colorado River. Several bills establishing game reserves throughout the state passed, as did several bills regarding highway laws, including the creation of the State Highway Department and some “Rules of the Road”. Several water bills passed: One appropriating money for the “Protection of Waters” to investigate and prepare to defend water rights; several authorizing various commissioners to negotiate water rights compacts between Colorado and neighboring states regarding the Arkansas, Colorado, La Plata, Laramie, and South Platte rivers; and several more regarding irrigation districts. The General Assembly passed Senate Concurrent Resolution No. 3 “Submitting to the qualified electors of the State of Colorado the question of holding a convention to revise, alter and amend the Constitution of the State of Colorado”. The ballot question was one of 10 ballot measures voted on in 1922 and lost 63% to 36%.

    The legislature also passed several “relief” bills appropriating money for individuals, including one for Mrs. Edna B. Mulnix whose 11-year-old son was crushed by an elevator at the State Capitol Building the year before. The legislature passed several constitutional amendments, including amendments regarding property rights of aliens, establishing the elections of county officials, putting certain educational institutions under the management and control of the state, and setting terms of office for state officers, all to be voted on by Coloradans at the next general election. The legislature enacted a bill appropriating money for “correct lists” of the battles in which Colorado solders participated and of the names of Colorado soldiers who died or were killed in Civil War battles to be placed on tablets on the Monument to Colorado Soldiers on the west side of the Capitol Building. And the legislature adopted Senate Joint Resolution No. 19, placing a memorial stained glass window for David Halliday Moffat in the Senate chambers. On the last day of session, the House and Senate, between forming conference committees and adopting and rejecting reports and concurring and receding from positions, received “some candy for the lady members and clerks, some cigars for the men and some apples for all” as a show of appreciation and finally adjourned sine die at midnight on April 5, 1921.

    How does this compare to today?

    Luckily, we are not recovering from a devastating world war but we have experienced the devastation of a worldwide pandemic and the emotional and economic hardships resulting from losing family members and closing businesses. It has also been quite the year of social unrest. Based on the legislative leadership’s remarks at the beginning of the 2021 session, the top issues facing the legislature are helping the state recover from the current public health crisis, ushering in a quick economic recovery, getting any stimulus money to those who need it as quickly as possible, and assisting unemployed Coloradans. Other issues include addressing disparities in the health care system, criminal justice reform, law enforcement reform, lowering the cost of living, adequate highways and roads, meeting energy needs, and addressing systemic discrimination. The times may have changed, but many of the issues remain much the same.

    Sources:

    https://lawcollections.colorado.edu/colorado-house-and-senate-journals/

    https://lawcollections.colorado.edu/colorado-session-laws/

    http://www.leg.state.co.us/lcs/ballothistory.nsf/

    https://en.wikipedia.org/wiki/Colorado_Mounted_Rangers

  • Tribute, Resolution, or Memorial – Making the Right Choice

    By Patti Dahlberg

    Editor’s note: This article was originally posted on February 1, 2018, and has been edited as appropriate.

    When legislators wish to show support for individuals or groups, make public statements about issues or concerns, or ask Congress to take action on a matter, they may request a tribute, resolution, or memorial to get the job done. Legislators decide what they wish to do, and the legislative rules direct them how to get it done.

    This handy guide sums up these rules for making the right choice. For example, if a legislator wants to congratulate someone, a tribute is the way to go. It is an appropriate and efficient way to send congratulations to people or organizations or to recognize service to the state. In fact, whenever a legislator wishes to “officially” congratulate, recognize, express appreciation, commemorate, or even create a day of recognition, the rules pretty much scream “tribute”.

    Tributes

    Tributes are non-legislative actions and DO NOT require introduction, calendaring, or floor action.

    Tributes are a very efficient and effective way for legislators to show support for individuals or groups. Legislators are not limited in the number of tributes they may request, but they do need permission from the Speaker of the House or the President of the Senate (depending on the house of origin) before the tribute can be issued. The tribute’s content is unique to each request and is designed to fit the needs of each requestor. It may be short and created fairly quickly, or it may be longer and more detailed (based on information provided by the legislator). Tributes are easier to present to an individual or a group as they can be scheduled around the recipient and legislator’s calendars rather than the legislative calendar.  In addition, they can go on the road—the legislator can conveniently award them anywhere and any time.

    Tributes are personalized and look special. They are printed in a special font, on special paper, and placed in a special folder or, if preferred (and at a slight cost), in a frame for display. Tributes are signed by the Speaker or the President, as appropriate, or, in the case of joint tributes, both.

    House Tributes:

    • The House will not issue a tribute unless the Speaker of the House has given permission;
    • The Chief Clerk of the House maintains copies of each tribute issued for two years.

    Under House Rule 26A, a request should be a tribute if it pertains to any of the following:

    • Offering congratulations for significant public achievement;
    • Recognizing meritorious individual achievement;
    • Expressing appreciation for service to the state or the General Assembly;
    • Recognizing an individual’s service in the military (except in the case of recognizing an individual who died while serving, which may be done by House Resolution or Joint Resolution, see House Rule 26 (a)(2)(C));
    • Extending greetings to prominent visitors to the state;
    • Recognizing or commemorating any individual, organization, or group for a significant event or accomplishment;
    • Congratulating the members of an academic or athletic organization for achieving a specific historical, scientific, educational, or athletic goal, such as winning a league, state, or national title, competition, or championship; or
    • Designating a specified day for observing any of the achievements, events, service, or accomplishments set forth above.

    Senate Tributes:

    • Tributes are signed by the President of the Senate;
    • Tributes are printed in the journal every Friday;

    Under Senate Rule 30A, a request should be a tribute if it pertains to any of the following:

    • Offering congratulations for significant public achievements;
    • Recognizing meritorious individual achievement;
    • Expressing appreciation for service to the state or the General Assembly;
    • Recognizing an individual’s service in the military; or
    • Extending greetings to prominent visitors to the state.

    The House and the Senate Rules state that a request should be a Memorial Tribute or a Joint Memorial Tribute if it expresses sentiment on the death of a person who has not served as a member of the General Assembly (except for the House exceptions listed above regarding military, law enforcement, and firefighting personnel who died while serving) or, in the Senate, meets the exceptions allowed under the rules for Senate Memorials and Joint Memorials in Senate Rule 30 (d).

    All requests for tributes must be submitted to the Chief Clerk of the House or the Secretary of the Senate, as appropriate, or to their designated staff.

    Resolutions

    Resolutions are non-statutory actions but DO require introduction, calendaring, and floor action.

    House Resolutions:

    • Representatives are limited to a total of two resolutions or joint resolutions, unless they receive special permission.
    • Resolutions and joint resolutions must be introduced prior to the last thirty legislative days as required in Joint Rule 23 (g).
    • Upon introduction, they are read into the record by title only and copies are printed.
    • At the discretion of the Speaker, they can either be laid over for one day before being acted on or referred to a committee of reference.
    • No action is taken on the resolution or joint until it is printed.

    Under House Rule 26, House Resolutions or House Joint Resolutions pertain to:

    • Transacting the business of the House or the House and the Senate;
    • Establishing committees comprised of House members or members of both houses;
    • Recognizing an individual member of the armed forces of this country who has died while serving in the armed forces or an individual member of a police, sheriff, or fire department who has died while performing duties for the department;
    • Recognizing a national holiday; or
    • Expressing the will of the House or both houses on a matter not mentioned in House Rule 26A (i.e., not a tribute).

    In addition, but only in the House, pursuant to House Rule 26 (a)(3.5):

    • The Speaker, after consulting with the Majority Leader, may approve up to six resolutions for introduction recognizing or commemorating an individual, organization, or group for a significant event or accomplishment (i.e., which would normally have to be addressed through tributes); and
    • The Speaker, after consulting with the Minority Leader, may approve up to four resolutions for introduction recognizing or commemorating an individual, organization, or group for a significant event or accomplishment (i.e., which normally would have to be addressed through tributes).

    Senate Resolutions:

    • Senators are limited to a total of three resolutions or joint resolutions, unless they receive special permission.
    • Resolutions and joint resolutions must be introduced prior to the last thirty legislative days as required in Joint Rule 23 (g).
    • Upon introduction, they are printed in the journal by title only and copies are printed.
    • At the discretion of the President, they can be acted on immediately, laid over, or referred to a committee of reference.
    • Resolutions and joint resolutions that the Majority Leader identifies as noncontroversial may be placed on the consent calendar.

    Under Senate Rule 30, Senate Resolutions or Senate Joint Resolutions pertain to:

    • Transacting the business of the Senate or the House and the Senate;
    • Establishing investigating committees comprised of Senate members or members of both houses; or
    • Expressing the will of both houses on a matter not mentioned in Senate Rule 30A (i.e., not a tribute).

    All requests for resolutions and memorials must be submitted to the Office of Legislative Legal Services. In 2021, the deadline for requesting resolutions and memorials is Monday, May 10, and the deadline for introducing resolutions is Friday, May 14.

    Memorials

    Memorials are non-statutory actions but DO require introduction, calendaring, and floor action.

    House Memorials:

    • At the discretion of the Speaker, a former member of the House may be admitted to the House floor to address House members regarding the person being memorialized.
    • The House must stand in recess to hear an address by a former member.

    Under House Rule 26, the request is a House or House Joint Memorial if it expresses sentiment on the death of a person who served as a member of the General Assembly.

    Senate Memorials:

    • At the discretion of the President, a former member of the Senate may be admitted to the Senate floor to address Senate members regarding a memorial expressing sentiment on the death of a person who served as a member of the Senate.

    Under Senate Rule 30, the request is a Senate or Senate Joint Memorial if:

    • It expresses sentiment on the death of a person or persons who served as members of the General Assembly, current or former elected State officials, current or former justices of the Colorado Supreme Court, members of Congress, elected officials of other states or of the United States, or foreign dignitaries; or
    • It memorializes the U.S. Congress on any matter.

    All requests for resolutions and memorials must be submitted to the Office of Legislative Legal Services. In 2021, the deadline for requesting resolutions and memorials is Monday, May 10, and the deadline for introducing resolutions is Friday, May 14.

  • Throwback Thursday: Looking Back at 1921 and the Twenty-third General Assembly – Part 1

    by Patti Dahlberg

    If we went back fifty regular legislative sessions and one hundred years, what would we find?

    In Colorado, as a result of the November 1920 election (the first national election in which women were able to vote), Republicans retained control of the Colorado House of Representatives with 58 Republicans to seven Democrats, and Democrats lost control of the Colorado Senate with 24 Republicans to 11 Democrats.

    Coloradans passed four ballot measures:

    Six ballot measures failed:

    • Four initiatives: “Practice of chiropractic and providing for the regulation and licensing thereof”, “Creating the County of Limon”, “Creating the County of Flagler”, and “Providing for the construction of the Moffat, Monarch, and San Juan tunnels and a bond issue therefor”; and
    • Two referred measures: “Increasing the salaries of the Governor, the Secretary to the Governor, Justices of the Supreme Court, and judges of the district courts” and “Increasing the number of county judges”.

    So what was the economic, political, and social climate in America leading up to the 1921 legislative session?

    In September of 1920, America suffered the worst terrorist attack in its history (at least until the 1995 Oklahoma City Bombing) when a large explosive on a horse-drawn carriage was detonated on a busy Wall Street corner. The explosion killed 38 people and injured hundreds of others. In Colorado, the Denver Tramway Strike of 1920 left seven people dead and 50 injured. The Ku Klux Klan, founded during Civil War Reconstruction and known for violence against Blacks, reemerged in the 1920s and started targeting immigrants and certain religious organizations. The Klan tied their messages to the issues of prohibition and clean living. Finding a more mainstream audience as a result, they became involved in local and state politics in many states. Several race riots took place across the country, most notably the Tulsa race massacre where mobs of white residents destroyed 35 square blocks of a predominantly Black business district, leaving at least 35 people dead, and more than 800 people hospitalized. Historians now believe that up to 300 people may have died due to the violence.

    On a brighter note, women won the right to vote when the 19th Amendment was ratified by two-thirds of the states on August 18, 1920, (Colorado ratified the 19th Amendment on December 15, 1919, during a special legislative session) and in the November election, Colorado elected three women to serve in the Colorado House of Representatives. Colorado actually initiated female representation in its House of Representatives in 1895 when the citizens elected Clara Cressingham, Carrie Holly, and Frances Klock. The electronic news media was born when a Pennsylvania radio station began airing regular news broadcasts.

    The economic prosperity and freewheeling social spirit associated with the Roaring Twenties started with a struggling economy. The Spanish flu pandemic killed around 675,000 Americans (50 million people worldwide) before it was all over. A great number of the flu deaths were among working-age adults, and economists have suggested that the flu was responsible for a six to eight percent decline in worldwide gross domestic product. In addition, the adjustment from a wartime to peacetime economy proved to be a shock to the U.S. economy. Factories had to shut down completely or shut down until retooled to produce other products. Another factor that may have contributed to the economic downturn was a surge in the civilian labor force created when the troops returned from the war, adding to unemployment numbers and wage stagnation. In 1918, the Armed Forces employed 2.9 million people, which fell to 380,000 by 1920. As Europe recovered from war devastation, its agricultural output increased, causing a decline in American agricultural commodity prices. The Dow Jones hit a peak of 119.6 on November 3, 1919, only to spiral downward for the next 20 months, finally bottoming out at 63.9 (a 47% decline) on August 24, 1921. 1920 was a terrible year for businesses; those that did not fail saw huge declines in profits. All these factors combined to cause a deflationary recession, later known as the Depression of 1920-1921, lasting from January 1920 to July 1921.

    In Colorado, probably few people anticipated the economic impact the end of the war would have on our state. After all, the farming and mining industries, which had ramped up production to meet wartime demand, enjoyed an initially strong post-war market demand. But as Europe recovered and Europeans became less dependent on America for food and other products, prices fell and food producers found themselves hard pressed, especially on the plains of northeast Colorado. They had borrowed heavily to expand and cash in on the wartime bonanza. As returns diminished, debts were more difficult to service, and Coloradans were hurting.

    In the second part of our look back at 1921 and the Colorado Legislature, we’ll take a closer look at the start of the 23rd General Assembly and how it met the challenges of its time.

    Sources:

    http://www.strongsisters.org/the-elected-women/

    http://www.leg.state.co.us/lcs/ballothistory.nsf/

    https://www.britannica.com/event/Wall-Street-bombing-of-1920

    https://coloradoencyclopedia.org/article/denver-tramway-strike-1920

    https://www.pbs.org/wgbh/americanexperience/features/flood-klan/

    https://en.wikipedia.org/wiki/Depression_of_1920%E2%80%931921

    1921 Tulsa Race Massacre