Gallagher v. Board of Trustees for the University of Northern Colorado

Introduction

In this case we consider three issues construing the Colorado Governmental Immunity Act (CGIA) in the context of a whistle-blower claim.

First, we consider whether the CGIA's 180-day notice of claim requirement bars the whistleblower-plaintiff from seeking relief for actions of the defendant-employer which occurred more than 180 days before the employee filed notice of the claim. Second, we consider whether the continuing violation doctrine developed under cases interpreting Title VII's filing requirements applies to a determination of whether the CIA's 180-day notice of claim…