In a matter of first impression, the Colorado Court of Appeals considered whether campaign contributions can disqualify elected officials from serving as decision-makers in quasi-judicial proceedings under the due process clause.

The issue came before the appellate court after Larimer County Commissioner Tom Donnelly voted to support Loveland Ready-Mix Concrete Inc.’s application seeking a permit to operate a gravel mine and batch plant, which would process the mined material into concrete. The vote came after Ready-Mix contributed $4,100 to Donnelly’s reelection campaign in 2016, according to appellate court records outlining the case No Laporte Gravel v. Board of County Commissioners of Larimer County.