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Clerk Johnson next argues that the Secretary cannot issue an order unless the section ofthe law he is enforcing order specifically mentions the word “order” (Clerk’s SummaryJudgment Motion, pp. 12-13). Clerk Johnson bases her argument on the phrase “promulgated bythe secretary of state pursuant to this code.” Section 1-1-110(1). This interpretation leads to anabsurd result. The Secretary has the power “to inspect…and review the practices and proceduresof county clerks and recorders.. and other election officials in the conduct of primary, generaland congressional vacancy elections…” Section 1-1-107(2)(b), C.R.S. (2012). As noted, thesecretary has the authority to enforce and implement the laws, and in the context of mail ballotelection, to appoint the clerk as an agent. Clerk Johnson’s interpretation would mean that theSecretary could inspect and instruct, but could not enforce if the Clerk did not agree with theSecretary’s instruction.Clerk Johnson also argues that the 2012 rules do not supersede the 2011 order. (Clerk’sSummary Judgment Motion, pp. 13-14). The Secretary did not cite these rules to support hisargument that the County is bound by his rules. The Secretary cited the rules to support hisinterpretation of the provisions in the mail ballot statute.Clerk Johnson next contends that the Election Code provides a process through whichdisagreements may be resolved. (Clerk’s Motion for Summary Judgment, p. 14) There is noquestion that the Election Code establishes a procedure through which disagreements may bebrought to the attention of the courts by citizens who are eligible to vote. Eligible electors maychallenge a decision by the Secretary, the clerks or other election officials. Section 1-1-113(1),C.R.S. (2012). Thus, citizens, such as members of Common Cause, may bring challenges.What is generally not allowed is a challenge by a subordinate county official to an actiontaken by a state official. The Supreme Court rejected Clerk Johnson’s argument in Board of16