People ex rel. Losavio v. Gentry
In People ex rel. Losavio v. Gentry, 199 Colo. 153, 159, 606 P.2d 57, 61 (1980), the district court appointed a special prosecutor to investigate allegations of budgetary improprieties in certain county agencies, possibly including the district attorney's office.
The special prosecutor's investigation resulted in indictment of a county commissioner on charges of embezzlement of public property. Thereafter, the special prosecutor also sought to prosecute the county commissioner on a charge of theft of a trailer, which had nothing to do with budget improprieties.
The county commissioner challenged the special prosecutor's authority to investigate the alleged theft, and the supreme court held that the special prosecutor had exceeded his authority in investigating and prosecuting any matter beyond the scope of budgetary irregularities.