Background
Brenda Hancock sought judicial review of a final decision by the Colorado Department of Human Services. The Department had affirmed an administrative law judge’s summary judgment ruling upholding a county human-services department’s finding that Hancock committed moderate intrafamilial physical abuse of a child.
Proceeding without counsel, Hancock filed an amended form complaint under Colorado’s Administrative Procedure Act. She alleged that the proceedings were false and inaccurate, described the effects of the finding on her work and volunteer activities involving children and her relationship with her grandchildren, and sought reversal, remand, or modification of the final agency decision. The district court dismissed the complaint under Rule 12(b)(5) for failure to state a claim.
The Court’s Holding
The Colorado Court of Appeals reversed. Liberally construing Hancock’s pro se amended complaint together with the Department’s final decision attached to her initial complaint, the court concluded that she adequately pleaded a claim for judicial review under section 24-4-106.
The complaint identified the final agency decision being challenged, sought reversal or modification of that decision, and alleged that the proceedings were false and inaccurate. Although Hancock did not fully develop her legal theories, those allegations were sufficient at the pleading stage to give notice of her challenge. The court expressed no view on the merits of the agency decision.
Key Takeaways
- A complaint for judicial review of final agency action need only plausibly allege that the plaintiff was aggrieved, is entitled to relief, and seeks specified relief.
- Courts must liberally construe pleadings filed by self-represented litigants.
- A court may consider documents attached to or referenced in the complaint when deciding a motion to dismiss.
Why It Matters
The decision underscores that an administrative-review complaint need not contain fully developed merits briefing to survive dismissal. Where a pro se filing identifies the agency action, the requested relief, and a basis for contesting the action, the case should proceed to review on the merits.
The case was remanded with directions to reinstate Hancock’s amended complaint and conduct further proceedings.