Renee Sweet v. Douglas County Board of Commissioners

The following questions are presented:

1. Is a zoning resolution, having been adopted, a policy, or the equivalent in law of a zoning ordinance, having been enacted? Therein, being reasonably included: a. What is the scope of authority of a zoning resolution? i. That being, against whom does it apply; ii. Under what circumstances; iii. Whether or not engaging in business, commerce, trade, industry, or being subject to contract or license, is a prerequisite for a zoning resolution to adhere and be made enforceable pursuant to Colorado Revised Statutes (“CRS”) §§ 30-28-124(2) and 30-28-124.5; and iv. Whether or not the Douglas County Colorado Zoning Resolutions (“DCZR”) §§ 2 and 7, pertinent to this case, require a commercial, license or otherwise contractual nexus, or activity to adhere. v. As a consequence, do CRS Sections 30-28-124(2), 30-28-124.5 and DCZR §§ 208, 211.01 or 715.01, as applied, without a contractual nexus or commercial activity, instead of the use of zoning ordinances, constitute a due process violation, an unlawful property taking, or void for vagueness?

2. Does Petitioner have a Constitutional right to have the courtroom security recording produced so that the audio can be made available to complete the record on appeal; and so a determination can be made as to whom was responsible for turning off the FTR device, and should there be sanctions for deliberate spoliation of evidence, and of the record, during trial?