City of Westminster v. Dogan Construction Co.

This case presents the issue of whether the written results of telephone interviews with the references of a bidder on a municipal construction project, memorialized in notes on preprinted questionnaire forms, are “letters of reference concerning employment” for the purposes of the Colorado Open Records Act (Act). See §§ 24-72-201 to -206, 10B C.R.S. (1988 & 1996 Supp.). Dogan Construction Company, Inc. (Dogan), a bidder on a large construction project for the City of Westminster (City), brought an action seeking to compel the City to permit inspection of questionnaires that the City had used…