2nd Emergency Injunction Federal unemployment, Doc. 37-1 — D. Colo., CourtListener docket 239393

Date: 2025-02-26

Summary

Plaintiff's Second Emergency Motion for Injunctive Relief Regarding Unpaid 2023 Benefits, filed May 12, 2025 as Document 37-1 by pro se plaintiff Joshua Abrams in Abrams v. Division of Unemployment Insurance, et al., Case No. 1:24-cv-03390-RMR, in the U.S. District Court for the District of Colorado. The motion supplements an Emergency Motion filed February 26, 2025 and seeks relief over $6,000 in unpaid 2023 unemployment benefits. It alleges that the Division imposed integrity holds without appealable determinations and excluded out-of-state wages from his benefit calculation, and argues violations of the First and Fourteenth Amendments and Title II of the ADA. It applies the four-factor test under Fed. R. Civ. P. 65 and asks for systemic changes, added staffing and a Special Master under Fed. R. Civ. P. 53. Exhibits A, B and C are attached.

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Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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FILED
UNITED STATES DISTRICT COURT 1
DENVER, COLORADO
9:40 am, May 12, 2025

JEFFREY P. COLWELL, CLERK

The United States District Court District of Colorado
901 19th St, Denver, CO 80294 | (303) 844-3433
Plaintiff: Joshua Abrams
v.
Defendant(s): Division of Unemployment Insurance,
JOE BARELA | JEFF FITZGERALD | Etc. ▲COURT USE ONLY▲
Joshua Abrams, Pro Se | abramslive@gmail.com |720-910-4829 Case Number:
1881 E 112th Pl, Northglenn Colorado 80233 1:24-cv-03390-RMR
Division: Courtroom
Plaintiff’s Second Emergency Motion for Injunctive Relief
Regarding Unpaid 2023 Benefits

Plaintiff respectfully submits this Second Emergency Motion for Injunctive Relief to address

newly clarified and ongoing constitutional injuries that now pose an immediate threat to

Plaintiff’s survival. This motion supplements but is independent of the original Emergency

Motion filed February 26, 2025, which sought relief for the unconstitutional withholding of

Plaintiff’s 2025 unemployment benefits. While those benefits have since been released, the

structural harms remain unremedied and continue to produce compounding, irreparable damage.

This crisis began in 2023 when Defendants imposed a series of punitive “integrity holds” on

Plaintiff’s claim without issuing the legally required appealable determinations. This blocked

Plaintiff’s ability to seek any review or correction, effectively denying access to due process and

meaningful petitioning rights. These same unresolved integrity issues rolled forward into 2025,

where they again delayed benefits and depleted Plaintiff’s last financial reserves. The $6,000 in

unpaid 2023 benefits remains outstanding and critical to Plaintiff’s ability to avoid eviction,
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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access medicine, and remain stable as current unemployment payments are set to expire within

four weeks.

These are not isolated administrative errors. They reflect ongoing systemic failures that violate

the First and Fourteenth Amendments and Title II of the ADAfailures that affect thousands of

similarly situated Coloradans. Claimants continue to report stalled claims, no issued decisions,

inaccessible appeal systems, and a total lack of ADA-compliant communication or

accommodation pathways. Defendants’ own declarations confirm they lack the staffing and

procedures to meet even baseline constitutional and statutory obligations.

Plaintiff has already submitted comprehensive evidence and briefing, including sworn testimony,

exhibits, and government records, detailing both personal and systemic violations. Defendants,

despite being granted an extension, failed to rebut this record. Their omission must be treated as

a concession. At this stage, the Court must decide whether to intervene meaningfully, to prevent

not only further harm to this Plaintiff, but to halt a system that continues to violate the rights of

thousands under color of law.

This situation is not sustainable. The Court is now the only meaningful forum available to

prevent a foreseeable and preventable humanitarian disaster.

These systemic constitutional violations are not isolated to Plaintiff alone. They represent an

entrenched and ongoing administrative failure affecting thousands of Colorado residents, many

of whom, like Plaintiff, are disabled, indigent, or otherwise vulnerable. Through public forums

including Reddit, Facebook, Nextdoor, Google Maps reviews, and claimant advocacy groups,

Plaintiff has documented the widespread frustration and suffering of citizens who remain trapped

in a system that denies them the most basic constitutional and statutory protections.
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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Hundreds of individuals describe near-identical patterns where applications indefinitely stalled

under integrity holds; no appealable decision issued within the promised 7-day window; phone

systems that disconnect or loop endlessly; document upload portals that are entirely unmonitored

unless a live agent manually escalates the file an action that is statistically impossible for most

claimants to obtain. In sworn declarations, Defendants themselves admit that the call center is

severely understaffed and would require at least 60 additional agents just to support a callback

system, which is currently unavailable. This systemic breakdown is not theoretical; it is lived

daily by Coloradans already at the edge of survival.

Claimants report losing housing, falling into credit collapse, going without food or medicine, and

being unable to treat medical conditions due to the unlawful withholding of benefits. The process

disproportionately harms those least able to navigate bureaucratic barriers disabled individuals,

non-native English speakers, elderly claimants, and low-income families with no access to legal

assistance. The absence of accessible appeals pathways, meaningful communication channels, or

standard due process safeguards has made the entire unemployment framework functionally

unconstitutional. Claimants have no right to appeal if the agency never issues a disqualification;

no right to be heard if they can’t reach a representative; and no right to accommodations if the

system provides no means to request them.

This conduct is indefensible not merely as a litigation tactic, but as a failure of professional

responsibility and constitutional duty. While Defendants may vigorously defend against claims,

they are not permitted to disregard uncontested evidence or to weaponize procedural mechanisms

to deepen the harms they are duty-bound to resolve. The deliberate refusal to acknowledge

claims of systemic harm, when armed with full knowledge and ample legal resources, is not
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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advocacy, it is complicity. This Court should treat the unrebutted supplemental record as

admitted, and weigh this omission heavily in favor of injunctive relief.

In contrast, the Defendants represented by two separate attorneys paid by the State of Colorado

have failed to engage in good faith. They do not acknowledge the harm. They do not dispute the

facts presented in critical filings. They instead construct artificial narratives, rely on theoretical

frameworks that are proven non functional, mischaracterize the record, and seek refuge in

strained interpretations of immunity, exhaustion, and procedural diversion. In doing so, they

knowingly add to the burden suffered by the very citizens they are charged to serve. They have

violated not only federal law, but the moral oath that accompanies public service.

Meanwhile, Plaintiff’s pending appointment of counsel under 28 U.S.C. § 1915(e)(1) remains

unaddressed, even as the State directs public funds toward defending unconstitutional systems

with 2 separate attorneys while investing nothing in investigating or rectifying the harm suffered

by its most vulnerable citizens and forcing further reliance and demand on a Plaintiff who’s

already indigent and disabled and self represented reveals a new 14th amendment equal access

violation if justice continues to and cannot correct this imbalance. The disparity between

Plaintiff’s unrepresented status and the State’s taxpayer-funded counsel implicates equal

protection under Gideon v. Wainwright, 372 U.S. 335, 344 (1963).

Congress created unemployment insurance to stabilize families, protect public health, and avert

cascading economic ruin. Defendants’ continued reliance on abstract legal defenses while

refusing to engage the substance of this reality speaks not only to the weakness of their legal

position, but to the broader institutional indifference that this action seeks to correct.
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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Plaintiff filed an Amended Complaint, followed by an Emergency Injunction on February 26,

2025, and supplemental briefing on March 25, 2025. Defendants were granted an extension to

respond. Their April 28 response failed to rebut the March 25 brief or address core constitutional

claims. This omission, under Tenth Circuit precedent, may be deemed a concession. This second

motion seeks injunctive relief for unresolved constitutional injuries, including ongoing denial of

$6,000 in underpaid benefits.

Factual Background

Plaintiff applied for unemployment benefits and properly included his out-of-state wages, as

required under federal law. The Division, however, failed to include those wages in the benefit

calculation, resulting in a significant underpayment. Despite repeated attempts to correct this

error via phone, fax, and in personPlaintiff was denied any meaningful process or avenue for

review. Rather than addressing the miscalculation, Division representatives instructed Plaintiff

that the only way to “recalculate” his benefits was to withdraw his existing application and file a

new one, even though his original application was complete and legally sufficient.

These systemic failures culminated in Plaintiff being forced out of sheer desperation to attend

in-person appointments that were advertised as offering meaningful relief in 2023, but in practice

did not. As an indigent, disabled individual with no access to legal representation or reliable

communication, Plaintiff had no choice but to board overcrowded public buses and trains to

reach CDLE offices, only to be placed in unsanitary, unventilated rooms containing a single

shared landline telephone. These rooms offered no direct human assistance, no ADA-compliant

accommodation, and no cleaning or sanitization between uses despite the ongoing pandemic and

visible signs of illness among other claimants. Plaintiff was exposed to and contracted
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COVID-19 and later developed conjunctivitis after using this shared equipment, resulting in

serious and prolonged medical hardship that interfered with job seeking efforts, worsened his

disability, and caused further economic destabilization. The Defendants offer no justification for

these hazardous and dehumanizing conditions, instead asserting broad immunity that does not

shield them from injunctive relief or consequences for ongoing constitutional and statutory

violations. These physical harms were a direct and foreseeable result of a deliberately

inaccessible, constitutionally deficient process that disproportionately injures the most vulnerable

those already sick, homeless, or disabled under the color of administrative legitimacy.

Subsequently, the Division issued a determination that Plaintiff had been denied the right to

withdraw his application. Plaintiff contacted the appeals hotline and was informed that this was

the only appealable issue on file. With no way to challenge the underpayment directly, Plaintiff

submitted an appeal not to withdraw the application, but expressly to challenge the Division’s

error in calculating benefits. Plaintiff’s intent was clearly stated in both the appeal form[See

Exhibit A] and the accompanying documents. Nevertheless, the appeal was denied by the

magistrate on procedural grounds, based solely on an untimely request to withdraw[See Exhibit

B] despite the fact that Plaintiff had never requested to withdraw at all.

As shown in [Exhibit C], Plaintiff’s North Carolina employment with Apex Systems and Tek

Systems was properly disclosed, recorded, and visible in the official CDLE claimant portal as of

April 10, 2023. These out-of-state wages were part of Plaintiff’s initial claim and should have

been factored into his benefit eligibility and payment calculation. Despite this, Plaintiff was

repeatedly denied any avenue to correct the underpayment, even after multiple phone calls and

follow-ups. Supervisors acknowledged the error yet disclaimed the authority to fix it, citing a

nonexistent or inaccessible “out-of-state specialist process” that lacked transparency, tracking, or
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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timelines. Defendants' phone agents ultimately advised Plaintiff to “just wait,” promising without

basis that the issue would resolve itself automatically despite knowing full well it would not.

This institutional practice of knowingly deflecting or misinforming indigent claimants to satisfy

internal call metrics rather than ensuring lawful benefit determinations is not only unethical, it is

unconstitutional. Defendants’ own admissions and this record confirm that the denial of

Plaintiff’s full benefits was not due to missing information or claimant error, but due to

administrative negligence compounded by deliberate obstruction.

Plaintiff had the ‘technical’ right to appeal and escalate that denial further, but doing so would

have been futile and harmful to the Plaintiff. It was clear from the magistrate’s ruling that the

scope of any review was artificially limited to the withdrawal determination and would not

address the actual issue: the underpayment of benefits. Pursuing that appeal would not only fail

to resolve the harm, but also risked further delay in processing and disbursement or jeopardizing

the limited benefits Plaintiff was already receiving. Refiling the same application at a later date

would likewise not remedy the due process violations that had already occurred.

Defendants now argue that Plaintiff failed to exhaust administrative remedies by not continuing

to appeal the withdrawal determination which is a procedurally unrelated and substantively

irrelevant issue. This defense deflects from the constitutional violation itself: that Plaintiff was

denied any process to challenge the actual harm. The system forced Plaintiff into a false choice

between sabotaging his claim or forfeiting his right to petition. That is not administrative

exhaustion; it is a textbook example of an unconstitutional process designed to prevent appeal,

block redress, and obscure accountability.
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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Plaintiff clearly meets the four-factor standard for issuance of preliminary injunctive relief under

Fed. R. Civ. P. 65, as articulated by the Tenth Circuit in Free the Nipple-Fort Collins v. City of

Fort Collins, 916 F.3d 792 (10th Cir. 2019). Specifically, Plaintiff demonstrates: (1) substantial

likelihood of success on the merits; (2) irreparable harm absent the injunction; (3) a favorable

balance of equities; and (4) that an injunction serves the public interest.

(1)Likelihood of Success on the Merits : Plaintiff's claims arise under the Ex Parte Young

doctrine, which allows federal courts to grant prospective relief against ongoing constitutional

violations by state officials. See Verizon Md., Inc. v. Pub. Serv. Comm’n, 535 U.S. 635, 645

(2002). Plaintiff has extensively documented, through sworn testimony and undisputed

administrative records, multiple violations of federal law, including due process, First

Amendment rights, and Title II of the Americans with Disabilities Act (ADA).

Under Goldberg v. Kelly, 397 U.S. 254 (1970), and Mathews v. Eldridge, 424 U.S. 319 (1976),

due process mandates that claimants receive clear and timely notice of benefit denials and a

meaningful opportunity to contest such denials. Here, Plaintiff was subjected to three separate

integrity holds by Defendants in 2023 without ever receiving formal notices or appealable

determinations especially on the 3rd. Defendant deflects it’s duty without argument simply

referencing the Plaintiff returned to work in the late quarter, notable well after the 7 day required

time to issue a determination and even with employment doesn’t nullify their obligation to issue

notices and decisions, especially since they used that as justification in delaying and denying

benefits in 2025 for a completely new claim. This systemic failure to provide legally required

notice and meaningful appeal mechanisms constitutes an ongoing violation of Plaintiff’s due

process rights.
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Defendants' actions inherently violated Plaintiff’s Fourteenth Amendment right to due process.

By effectively blocking Plaintiff from accessing meaningful and relevant appeals, Plaintiff was

never afforded the opportunity to present evidence, documentation, or legal authority challenging

the erroneous calculations that resulted in his underpayment of benefits. Specifically, Defendants

improperly excluded out-of-state wages that federal law explicitly required them to include.

Plaintiff had no mechanism to correct these errors or receive an appealable determination

regarding this deprivation, thus constituting a direct violation of Plaintiff’s due process rights

under the Fourteenth Amendment by depriving Plaintiff of property without any meaningful

opportunity to be heard.

Plaintiff’s First Amendment right to petition for redress has been effectively nullified by

Defendants’ procedural framework, which conditions the appeal process upon receipt of a

particular type of predetermined administrative notice. Such notices frequently do not exist, are

never generated, or are issued exclusively for irrelevant matters. Consequently, claimants face a

scenario wherein legitimate grievances related to underpayment, employer disputes, or integrity

issues cannot be appealed because Defendants restrict appeals exclusively to narrowly defined

and selectively issued administrative determinations. Specifically, Plaintiff was compelled to

appeal an irrelevant determination concerning the withdrawal of an application, a determination

entirely unrelated to the substantive issues of underpayment and integrity held by Plaintiff.

Defendants assert Plaintiff failed to exhaust administrative remedies, but exhaustion is excused

where remedies are constitutionally unavailable or where pursuing them would cause further

harm. The only available appeal route concerned ‘withdrawing’ an application Plaintiff never

sought to withdraw. Pursuing that irrelevant appeal would have worsened Plaintiff’s situation and

left the underlying issue, the underpayment completely untouched. This structural denial of
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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access itself constitutes a due process violation Defendants now assert, without legal basis, that

Plaintiff's inability or refusal to engage in an irrelevant and detrimental appeal process

constitutes a failure to exhaust administrative remedies.

Defendants' argument in this respect not only lacks legal merit but exposes their bad faith and

deliberate attempts to evade accountability for systemic constitutional violations. To suggest

Plaintiff failed to exhaust remedies when no meaningful remedy was ever made available is

legally untenable and factually disingenuous. Further, the Defendants' insistence on forcing

Plaintiff into pursuing harmful and irrelevant appeals underscores their deliberate disregard for

constitutional rights and statutory obligations. This approach highlights the Defendants'

unwillingness to provide genuine administrative relief, and instead demonstrates their reliance on

obstructionist tactics designed to frustrate valid constitutional claims. Consequently, Plaintiffand

numerous similarly situated individuals lack any viable means to contest the wrongful

deprivation of essential unemployment benefits. This functional denial directly infringes upon

the fundamental right of access to courts, clearly established in Bounds v. Smith, 430 U.S. 817

(1977).

Plaintiff has a substantial likelihood of prevailing on ADA claims. Defendants acknowledge in

their own declarations that the system lacks any formal, accessible mechanism for disabled

claimants to request necessary accommodations, leaving individuals unable to use phone services

or travel physically without meaningful access to critical unemployment services. This systemic

deficiency violates the ADA’s mandate that public entities provide accessible and effective

accommodation methods. See Tennessee v. Lane, 541 U.S. 509 (2004).
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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(2) Irreparable Harm : Plaintiff has suffered, and continues to suffer, significant irreparable

harm due to Defendants’ actions. Courts consistently recognize constitutional violations as

inherently irreparable because they damage fundamental rights beyond mere monetary loss.

Elrod v. Burns, 427 U.S. 347, 373 (1976). Plaintiff’s documented harm includes the denial of

essential unemployment benefits, loss of medical coverage through Medicaid resulting in

significant medical expenses, housing instability, damaged credit, and severe emotional distress

all ongoing injuries stemming directly from Defendants’ constitutional and statutory violations.

These harms are tangible, immediate, and not compensable by retrospective monetary relief

alone. Each day without an injunction exacerbates Plaintiff’s deteriorating health, economic

security, and overall well-being. Plaintiff’s sworn affidavits and supporting documentation

already submitted into evidence substantiate these irreparable harms.

(3)Balance of Equities : The balance of equities decidedly favors Plaintiff. Defendants face

minimal, if any, burden in complying with constitutional and statutory mandates already required

by law. Any administrative adjustments necessary to issue overdue benefit determinations,

provide a functional appeals process, and accommodate disabled individuals are routine

responsibilities of state agencies.

Conversely, Plaintiff faces dire and immediate threats to survival absent injunctive relief. The

equities thus overwhelmingly favor immediate judicial intervention to prevent further

deterioration of Plaintiff’s condition and secure compliance with clear constitutional and federal

obligations.

(4)Public Interest : The requested injunctive relief undeniably serves the public interest.

Upholding constitutional rights, ensuring due process, guaranteeing accessibility for disabled
Case No. 1:24-cv-03390-RMR Document 37-1 filed 05/12/25 USDC Colorado pg
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individuals, and requiring government agencies to follow statutory obligations benefit not only

Plaintiff but also countless similarly situated Coloradans facing systemic barriers.

Public records, performance reports, social media shows widespread citizen complaints, and

Defendants’ admissions confirm a broader crisis affecting thousands. Addressing these systemic

failures will directly enhance public welfare by strengthening the integrity and fairness of

Colorado’s unemployment benefits system.

Defendants cite Free the Nipple–Fort Collins v. City of Fort Collins, 916 F.3d 792 (10th Cir.

2019), in a manner that not only mischaracterizes its legal framework, but trivializes the depth

and urgency of the harm at issue here. That case involved a limited equal protection challenge

regarding the public display of the female chest, a matter of expression with abstract implications

and no direct economic consequence.

By contrast, Plaintiff’s case concerns widespread, ongoing constitutional violations that deprive

individuals of their basic ability to survive. Plaintiff has more than satisfied the Free the Nipple

standard for preliminary injunctive relief including likelihood of success, irreparable harm,

equitable balance, and the public interest but this case goes well beyond the expressive rights at

issue in Free the Nipple. Here, every day of delay threatens to push vulnerable claimants further

into poverty, eviction, untreated illness, or institutional harm. These harms are not theoretical.

They are ongoing, predictable, and, in some cases, fatal. The death certificate may not list

"denied unemployment" as the cause, but make no mistake this system’s failures are killing

people.

Plaintiff meets each prong required for preliminary injunctive relief. The violations alleged are

substantial, ongoing, and clearly established in law. The irreparable harm Plaintiff faces
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outweighs any minor administrative inconvenience to Defendants, and public interest undeniably

favors immediate judicial action. Accordingly, the Court should grant Plaintiff’s request for

emergency injunctive relief.

Relief Requested

Order Immediate Backpay: Issue an injunction compelling Defendants to pay Plaintiff the

$6,000 in wrongfully withheld 2023 unemployment compensation, which remains critical to

preventing imminent homelessness and medical destabilization. While this relief would satisfy

Plaintiff’s immediate needs to prevent irreparable harm, this alone doesn’t stop the irreparable

harm affecting the thousands of other Colorado citizens currently suffering.

Issue Declaratory Relief: Declare that Defendants' current systems and practices violate the

First and Fourteenth Amendments and Title II of the Americans with Disabilities Act (ADA).

Specifically, the Court should recognize that:

● Claimants have been deprived of procedural due process where no disqualifying determinations

or appealable decisions were issued.

● The lack of accessible and functional channels to petition for redress violates First Amendment

protections.

● Defendants’ failure to maintain an accessible, transparent, and inclusive system for requesting

disability accommodations constitutes an ongoing violation of the ADA.

● Formally recognize the existence of a constitutional emergency affecting thousands of claimants

across Colorado, as demonstrated through sworn testimony, public data, oversight reports, and the

evidentiary record.
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Allow or Invite Summary Judgment: Grant leave or invite Plaintiff to file a Motion for

Summary Judgment. Alternatively, the Court should specify what genuine issues of material fact,

if any, preclude such judgment at this stage, given that Defendants have failed to rebut Plaintiff’s

evidence or identify plausible legal defenses.

Mandate Structural Reform and Compliance:

● Require Defendants to immediately develop and implement accessible ADA accommodation

processes, including online and non-phone-based requests.

● Direct Defendants to expand their appeals framework to allow for appeals on all matters

impacting benefit eligibility or amounts, not just limited to pre-defined determinations.

● Order the creation of an emergency or expedited appeals track for claimants whose claims have

remained unresolved for more than 60 days and issue notices to all former and active claimants to

make them aware of these changes and their rights since simply enacting the changes won’t stop

the harm of the victims and claimants don’t know such a pathway newly exists.

● Require the allocation or hiring of sufficient personnel (estimated at 60 additional staff) to allow

for meaningful phone access and call-back functions.

Establish Dedicated Integrity Resolution Channel: Order the creation of a separate and

constitutionally compliant integrity hold resolution process that is not dependent on access to the

claimant portal or main overburdened phone lines. This process must:

● Allow claimants to prove identity and eligibility without requiring insecure or burdensome digital

uploads of sensitive personal documents.

● Compliance with the Privacy Act of 1974, the Colorado Consumer Data Privacy Act, and HIPAA.

● Provide transparency and opt-out mechanisms regarding data sharing with third-party vendors

such as ID.me and Google Services.
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Appoint Special Master or other necessary relief : Appoint a Special Master under Fed. R.

Civ. P. 53 to oversee compliance, monitor systemic improvements, and ensure prompt

implementation of judicial orders considering the Defendant and their councils track record of

being non compliant spanning 2 decades of their control and positions.

________________________________________ Date:

05-11-2025 | ❑Petitioner/Plaintiff

Joshua Abrams, Pro Se

CERTIFICATE OF SERVICE

I certify that on 05-11-2025 a true and accurate copy of the Defendant was served on the other
party by:
X_E-filed, lauren.davison@coag.gov & Stephen.woolsey@coag.gov

__________________________________________

❑Petitioner/Plaintiff
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Exhibit A
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Exhibit B
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Exhibit C

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2nd Emergency Injunction Federal unemployment, Doc. 37-1 — D. Colo., CourtListener docket 239393

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