added.) €25 But unlike section 1988, "[nlo statutory equivalent exists under Colorado state law to enforce the state constitution." Vanderhurst v. Colo. Mountain Coll. Dist., 16 F.Supp.2d 1297, 1304 (D.Colo.1998). Nor have Colorado appellate courts "recognized an implied cause of action to enforce the provisions of the Colorado Constitution." Id. 1 26 In Board of County Commissioners of Douglas County v. Sundheim, 926 P.2d 545, 547 (Colo.1996), the supreme court analyzed whether it had "the authority to recognize an implied damages action in cases where citizens allege that government entities have violated their state constitutional rights." The court noted that under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619 (1971) (<HOLDING>), two instances exist "where creation of an
recognizing private damage action for fourth amendment violations by federal officers recognizing implied duty to market recognizing an implied fourth amendment action for damages recognizing that court precedent has implied that the exclusionary rule is a necessary corollary of the fourth amendment recognizing cause of action for damages against federal agents acting under their authority who allegedly violated plaintiffs fourth amendment rights