Halper v. San Miguel, 23CA1459

Mark L. Halper filed a complaint against three employees of the San Miguel County Sheriff’s Office, alleging a conspiracy to "frame" him by issuing a reckless driving citation.
Halper's complaint relied on a single factual allegation that Deputy Masters cited him after being directed by his superiors.
Halper asserted that the actions violated the criminal conspiracy statute and the office’s "Shared Ten Principles."
Defendants moved to dismiss for failure to state a claim under C.R.C.P. 12(b)(5).
The district court granted the motion, finding the complaint conclusory, lacking factual support, and insufficient to establish a legal claim.
Halper appealed the dismissal; the appellate court reviewed the matter de novo and affirmed the lower court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint stated a legal claim	Defendants conspired to frame Halper for reckless driving	Complaint lacked sufficient factual allegations or legal grounds	Complaint insufficient; dismissal affirmed
Basis for a civil action under criminal conspiracy statute	Actions violated criminal conspiracy law	No civil cause of action under criminal conspiracy statute	Such statute does not create civil liability
Violation of "Shared Ten Principles"	Principles create enforceable duties	Principles do not create any enforceable legal duty	No civil action based on internal principles
Allegations outside the complaint	Outside statements support claim	Only allegations in the complaint are relevant for dismissal standard	Only complaint/factual attachments considered

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleading)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility and specificity in pleadings)
Bly v. Story, 241 P.3d 529 (standard for de novo review of motion to dismiss)
Denver Post Corp. v. Ritter, 255 P.3d 1083 (courts need not accept legal conclusions as true)
Yadon v. Lowry, 126 P.3d 332 (scope of materials considered on motion to dismiss)