COLORADO AUTHORITY LIBRARY
Colorado Case Authority Library
The public guide tells you the rule. The authority library shows where the rule came from—and whether it is still safe to rely on.
Use the authority library as a verification layer
Move from the public guide to the controlling Colorado authority, then verify court level, publication status, later history, statutory changes and the exact issue decided before relying on a proposition.
Case law has a hierarchy—and a status
A citation is not enough. The court, publication status, later history, statutory amendments, and the exact issue decided determine how much weight the case should carry.
Current watch: Weatherill / Reynolds and Colorado Supreme Court No. 2026SC240
Two published Court of Appeals methods remain in tension
Reynolds v. Great Northern Insurance Co., 2023 COA 77 treats a § 10-3-1117 disclosure claim as subject to a one-year limitation with Day-31 accrual. Weatherill v. State Farm, 2026 COA 11M holds that the claim uses the two-year catchall period and discovery accrual, and expressly declines to follow Reynolds.
For publication control, do not say Weatherill “overruled” Reynolds. A Court of Appeals division cannot erase another published division decision. The conflict is precisely why Supreme Court review matters.
Source-control rules
- Opinion ≠ party brief.
- Petition ≠ grant.
- Grant ≠ reversal.
- Cert denial ≠ endorsement.
- Modified opinion controls over superseded text.
- Calendar the conservative deadline while the conflict remains material.
2026 Colorado decisions that changed or sharpened the library
Weatherill · 2026 COA 11M
Creates the current published conflict with Reynolds over § 10-3-1117 limitations and accrual.
Bohanan · 2026 COA 6
Separates statutory policy production from the insurer’s ultimate coverage determination.
Wenzell · 2026 CO 25
Clarifies § 10-3-1118 cooperation procedures and excess-UIM exhaustion.
Pinto · 2026 CO 44
Limits Schultz to bad-faith decision review and allows broader discovery for the contract claim.
Mostellar · 2026 CO 22
Reinforces the CGIA 182-day notice rule and injury-discovery trigger on the facts presented.
Nicola · 2026 CO 55
Applies the one-year post-death survival deadline under § 13-81-103(1)(b) in the circumstances presented.
Policy disclosure & coverage visibility
These cases govern or illuminate Colorado’s pre-suit automobile policy-disclosure system and the current limitations conflict under C.R.S. § 10-3-1117.
Weatherill v. State Farm Mutual Automobile Insurance Co.
2026 COA 11M · 589 P.3d 931 · Colorado Court of Appeals
Holds that a § 10-3-1117 claim is not a penalty action for limitations purposes, uses the two-year catchall period, and accrues on discovery or constructive discovery under § 13-80-108(8). The division expressly declined to follow Reynolds.
Reynolds v. Great Northern Insurance Co.
2023 COA 77 · 539 P.3d 930 · Colorado Court of Appeals
Treats a § 10-3-1117 claim as subject to a one-year limitations period and Day-31 accrual. Read together with Weatherill; do not describe either Court of Appeals division as overruling the other.
Bohanan v. Esurance Property & Casualty Insurance Co.
2026 COA 6 · Colorado Court of Appeals
Requires production under § 10-3-1117 notwithstanding the insurer’s later no-coverage position where the policy was potentially relevant when the statutory request was received; reinforces that disclosure and ultimate coverage are different questions.
Fogel v. Shelter Mutual Insurance Co.
Nos. 24-1422 & 24-1440 · 2026 WL 1430346 · U.S. Court of Appeals for the Tenth Circuit
Treats § 10-3-1117 as requiring disclosure of policies that might be relevant and rejects unilateral insurer gatekeeping over relevance. Federal authority applying Colorado law should be identified as federal, not as a Colorado Supreme Court holding.
UM/UIM coverage & first-party benefits
Colorado UM/UIM law is statutory, policy-specific, and intertwined with first-party claim handling. These cases answer distinct questions about exhaustion, insured status, offsets, consent, and payment of covered benefits.
State Farm Mutual Automobile Insurance Co. v. Fisher
2018 CO 39 · 418 P.3d 501 · Colorado Supreme Court
An insurer may violate §§ 10-3-1115 and -1116 by unreasonably delaying or denying an undisputed portion of covered UIM benefits even though other components of the claim remain reasonably disputed.
United Services Automobile Association v. Wenzell
2026 CO 25 · Colorado Supreme Court
Limits § 10-3-1118’s procedural failure-to-cooperate requirements to defenses arising from a policy’s general cooperation clause. It also holds that an excess-UIM exhaustion clause is satisfied when the insured demonstrates undisputed damages exceeding the maximum limits of all underlying policies.
Tubbs v. Farmers Insurance Exchange
2015 COA 70 · 353 P.3d 924 · Colorado Court of Appeals
A UIM insurer cannot enforce a policy provision requiring actual exhaustion of the tortfeasor’s liability coverage when the statutory UIM obligation is triggered by damages exceeding the liability limit.
Nibert v. GEICO Casualty Co.
2017 COA 23 · Colorado Court of Appeals
Explains that “fair debatability” is not itself dispositive of a statutory unreasonable-delay claim under §§ 10-3-1115 and -1116.
Vaccaro v. American Family Insurance Group
275 P.3d 750 (Colo. App. 2012) · Colorado Court of Appeals
Important Colorado UIM authority addressing benefit calculation and the relationship between statutory coverage and amounts available from other sources. Use the precise policy and statutory context before applying any offset rule.
State Farm Mutual Automobile Insurance Co. v. Brekke
105 P.3d 177 (Colo. 2004) · Colorado Supreme Court
A UM/UIM insurer does not simply step into the tortfeasor’s shoes on liability; first-party UM/UIM duties remain contractual and statutory even though the insured must establish legal entitlement to damages.
State Farm Mutual Automobile Insurance Co. v. Johnson
2017 CO 68 · 396 P.3d 651 · Colorado Supreme Court
Addresses accrual of a bad-faith UIM claim and the relationship between resolution of the underlying tort claim and later first-party bad-faith litigation.
Lauric v. USAA Casualty Insurance Co.
209 P.3d 190 (Colo. App. 2009) · Colorado Court of Appeals
Applies the notice-prejudice rule to UIM notice and consent-to-settle provisions. A settlement without required notice or consent is presumptively prejudicial, but the insured may rebut the presumption.
Claims handling, good faith & bad faith
These cases distinguish common-law bad faith, statutory unreasonable delay or denial, claim-file evidence, and ordinary contract disputes.
Travelers Insurance Co. v. Savio
706 P.2d 1258 (Colo. 1985) · Colorado Supreme Court
Foundational Colorado first-party bad-faith authority. The inquiry focuses on unreasonable insurer conduct and, for common-law bad faith, the insurer’s knowledge or reckless disregard of the unreasonableness.
Goodson v. American Standard Insurance Co.
89 P.3d 409 (Colo. 2004) · Colorado Supreme Court
Clarifies first- and third-party bad-faith concepts. Third-party bad faith concerns unreasonable investigation, defense, or settlement of claims asserted against the insured; first-party bad faith concerns unreasonable conduct toward the insured’s own benefits claim.
Schultz v. GEICO Casualty Co.
2018 CO 87 · 429 P.3d 844 · Colorado Supreme Court
Reasonableness of an insurer’s bad-faith decision is evaluated from information available when the decision was made. Fair debatability is relevant but does not by itself resolve bad faith; post-decision evidence cannot simply recreate the earlier claim decision.
In re Pinto v. United Services Automobile Association
2026 CO 44 · Colorado Supreme Court
Declines to extend Schultz’s time-of-decision discovery limitation to a breach-of-contract UM claim. Medical records, later insurance-claim documents, and an IME may be discoverable when relevant to proving contractual entitlement to UM benefits.
State Farm v. Fisher
2018 CO 39 · 418 P.3d 501 · Colorado Supreme Court
The existence of a genuine dispute over some damages does not authorize withholding an undisputed covered benefit. Fisher is a payment-timing authority as well as a UM/UIM case.
Policy interpretation, defense & indemnity
Coverage begins with the actual issued contract, but Colorado statutes and public policy can restrict what a policy may exclude or condition.
Hecla Mining Co. v. New Hampshire Insurance Co.
811 P.2d 1083 (Colo. 1991) · Colorado Supreme Court
Foundational complaint-rule authority: the duty to defend is broader than the duty to indemnify, and the insurer bears a heavy burden to avoid defense when allegations potentially or arguably fall within coverage.
Constitution Associates v. New Hampshire Insurance Co.
930 P.2d 556 (Colo. 1996) · Colorado Supreme Court
Reinforces the distinction between the duty to defend based on potential coverage and the narrower duty to indemnify based on actual covered liability.
Cyprus Amax Minerals Co. v. Lexington Insurance Co.
74 P.3d 294 (Colo. 2003) · Colorado Supreme Court
Important Colorado authority on defense and indemnity analysis, emphasizing policy text and the distinct functions of those duties.
Brennan v. Farmers Alliance Mutual Insurance Co.
961 P.2d 550 (Colo. App. 1998) · Colorado Court of Appeals
Illustrates that policy restrictions inconsistent with Colorado’s mandatory statutory coverage framework may be unenforceable.
Giampapa v. American Family Mutual Insurance Co.
64 P.3d 230 (Colo. 2003) · Colorado Supreme Court
Addresses enforcement of contractual insurance limitations and Colorado public-policy constraints. Read the precise policy provision and statutory context before applying the rule.
Auto-Owners Insurance Co. v. Bolt Factory Lofts Owners Association
2021 CO 32 · Colorado Supreme Court
Modern authority addressing insurer control, defense/settlement consequences, and insured self-protection when an insurer’s handling creates uncovered or excess exposure.
Liability settlement duties, excess exposure & releases
The settlement file is a chronology. These authorities address insurer control, protection of the insured, excess exposure, enforceable agreements, and release scope.
Aetna Casualty & Surety Co. v. Kornbluth
471 P.2d 609 (Colo. App. 1970) · Colorado Court of Appeals
Rejects both absolute insurer discretion and an automatic duty to accept every within-limits demand. Settlement conduct is judged by reasonableness under the circumstances.
Farmers Group, Inc. v. Trimble
691 P.2d 1138 (Colo. 1984) · Colorado Supreme Court
Foundational Colorado auto-liability settlement-duty authority. Insurer control over settlement carries a duty to act reasonably toward the insured facing possible excess exposure.
Lira v. Shelter Insurance Co.
913 P.2d 514 (Colo. 1996) · Colorado Supreme Court
The settlement duty follows covered exposure; an insurer is not required to fund uncovered punitive liability merely to eliminate every personal risk to the insured.
Bernhard v. Farmers Insurance Exchange
885 P.2d 265 (Colo. App. 1994) · Colorado Court of Appeals
A later policy-limits tender does not necessarily erase causally significant earlier settlement conduct.
Nunn v. Mid-Century Insurance Co.
244 P.3d 116 (Colo. 2010) · Colorado Supreme Court
Adopts the judgment rule and explains circumstances in which an insured may protect itself through assignment/covenant arrangements after unreasonable refusal to defend or settle.
State Farm Mutual Automobile Insurance Co. v. Goddard
2021 COA 15 · Colorado Court of Appeals
Whether rejection of a policy-limits demand was unreasonable ordinarily depends on the proof, timing, terms, liability picture, damages, and circumstances presented to the insurer.
Bunnett v. Smallwood
793 P.2d 157 (Colo. 1990) · Colorado Supreme Court
A release is a contract. Its construction begins with ordinary contract rules, the written language, and the parties’ objectively manifested agreement.
Yaekle v. Andrews
195 P.3d 1101 (Colo. 2008) · Colorado Supreme Court
Settlement agreements are contracts. Mutual assent and sufficiently definite material terms can create an enforceable agreement before a later long-form release is executed.
Artery v. Allstate Insurance Co.
984 P.2d 1187 (Colo. App. 1999) · Colorado Court of Appeals
Addresses unknown injury, worsening of known injury, intent, and mutual mistake in release litigation. For UIM consent/prejudice, later Lauric authority should be consulted separately.
Comparative fault, nonparties & allocation
Colorado uses modified comparative negligence and generally several liability. These cases explain the threshold comparison and the evidentiary requirements for assigning fault to nonparties.
Mountain Mobile Mix, Inc. v. Gifford
660 P.2d 883 (Colo. 1983) · Colorado Supreme Court
Adopts the combined-comparison approach: plaintiff negligence is compared against the combined negligence of the relevant tortfeasors for the statutory threshold.
Inland/Riggle Oil Co. v. Painter
925 P.2d 1083 (Colo. 1996) · Colorado Supreme Court
Applies combined comparison where fault is allocated to a designated nonparty and illustrates the role of an immune employer in the allocation framework.
B.G.’s, Inc. v. Gross
23 P.3d 691 (Colo. 2001) · Colorado Supreme Court
Reaffirms comparison of plaintiff fault against the combined fault of relevant defendants and designated nonparties.
Barton v. Adams Rental, Inc.
938 P.2d 532 (Colo. 1997) · Colorado Supreme Court
A nonparty-fault allocation must rest on admissible evidence supporting the nonparty’s contribution to the injury.
Redden v. SCI Colorado Funeral Services, Inc.
38 P.3d 75 (Colo. 2002) · Colorado Supreme Court
A valid nonparty designation requires a legally cognizable basis for fault, not merely an allegation that the nonparty’s conduct was part of the causal story.
Crash reports, evidence preservation & spoliation
Crash litigation depends on evidence that may disappear long before suit. These cases separate reporting rules from admissibility and govern consequences when relevant evidence is lost.
People v. Reyes
589 P.2d 1385 (Colo. App. 1979) · Colorado Court of Appeals
Distinguishes participant-required crash reports from police investigative reports for purposes of Colorado’s statutory confidentiality/evidentiary framework.
Aloi v. Union Pacific Railroad Corp.
129 P.3d 999 (Colo. 2006) · Colorado Supreme Court
Recognizes broad trial-court discretion concerning spoliation and adverse-inference consequences when relevant evidence is lost or destroyed.
Warembourg v. Excel Electric, Inc.
2020 COA 103 · 471 P.3d 1213 · Colorado Court of Appeals
Explains that spoliation consequences depend on the circumstances, including relevance and whether the missing evidence naturally would have been introduced.
Medical damages, collateral sources & property loss
Colorado separates damages proof from payment-source accounting. These cases govern what the jury may hear, post-verdict collateral-source treatment, medical-finance arrangements, and property valuation.
Wal-Mart Stores, Inc. v. Crossgrove
2012 CO 31 · 276 P.3d 562 · Colorado Supreme Court
Under the pre-verdict collateral-source rule, insurer-paid amounts are excluded in a qualifying case even when offered to show the reasonable value of medical services.
Volunteers of America Colorado Branch v. Gardenswartz
242 P.3d 1080 (Colo. 2010) · Colorado Supreme Court
Interprets § 13-21-111.6 and its contractual-benefit exception; benefits purchased for the injured person are not automatically deducted from the verdict.
Ronquillo v. EcoClean Home Services, Inc.
2021 CO 82 · 500 P.3d 1130 · Colorado Supreme Court
Examines medical-finance arrangements and whether discounted purchase amounts constitute collateral-source benefits.
Goodyear Tire & Rubber Co. v. Holmes
193 P.3d 821 (Colo. 2008) · Colorado Supreme Court
Supports Colorado’s before-and-after market-value framework for personal-property damage, an important anchor for vehicle-damage valuation.
Board of County Commissioners v. Slovek
723 P.2d 1309 (Colo. 1986) · Colorado Supreme Court
Foundational Colorado property-damage authority emphasizing that the damage measure should reasonably compensate the actual loss rather than mechanically apply a formula that over- or under-compensates.
Government vehicles & public-entity claims
Public-entity cases require a second clock. The Colorado Governmental Immunity Act can impose a nonclaim notice requirement long before an ordinary tort limitations period expires.
Ceja v. Lemire
154 P.3d 1064 (Colo. 2007) · Colorado Supreme Court
The CGIA motor-vehicle waiver did not apply where a county employee was acting within the scope of employment but driving a personally owned vehicle. Ownership/lease status is therefore a threshold fact.
Mostellar v. City of Colorado Springs
2026 CO 22 · Colorado Supreme Court
Reaffirms strict operation of the CGIA notice deadline and holds that the notice period begins with discovery of the injury rather than later discovery of another public entity’s potential liability on the facts presented.
Wrongful death & survival
A fatal crash can create separate survivor and estate claims. Current limitations and one-action consequences require independent analysis before settlement.
City of Grand Junction v. Nicola
2026 CO 55 · Colorado Supreme Court
Holds that § 13-81-103(1)(b) applies when a person under disability dies before the referenced limitation period expires, regardless of whether a legal representative was appointed, producing a one-year post-death deadline on the survival claims in that case.
Research queue — intentionally not promoted to publication-ready authority
The internal Colorado pilot contains additional cases and candidate authorities. They stay out of the public holding cards until the exact opinion, citation, proposition, later history, and current relevance are verified.
Publication QC protocol for every Colorado case card
Guide-to-authority crosswalk
| Guide topic | Principal cases in this library | Control question |
|---|---|---|
| Guide 03 · Find Insurance / Disclosure | Weatherill · Reynolds · Bohanan · Fogel | What must be disclosed, and what limitations/accrual rule presently governs? |
| Guides 04–05 · UM/UIM / Multiple Policies | Fisher · Wenzell · Tubbs · Nibert · Vaccaro · Brekke · Johnson · Lauric | What benefit is owed, under which policy, after which proof and preservation steps? |
| Guide 08 · Defense / Indemnity | Hecla · Constitution Associates · Cyprus Amax · Bolt Factory | Must the insurer defend now, and must it ultimately pay? |
| Guide 09 · Bad Faith | Savio · Goodson · Schultz · Pinto · Fisher | What did the insurer know, when did it know it, and was its conduct reasonable? |
| Guide 10 · Settlement / Excess | Kornbluth · Trimble · Lira · Bernhard · Nunn · Goddard | Did insurer-controlled settlement conduct reasonably protect the insured? |
| Guide 16 · Government Vehicle | Ceja · Mostellar | Is immunity waived, and was the CGIA notice gate satisfied? |
| Guide 17 · Comparative Fault | Mountain Mobile Mix · Inland/Riggle · B.G.’s · Barton · Redden | Who can receive a fault percentage, and what proof supports it? |
| Guide 18 · Investigation | Reyes · Aloi · Warembourg | What evidence exists, what is admissible, and what happened if evidence disappeared? |
| Guide 19 · Damages | Crossgrove · Gardenswartz · Ronquillo · Goodyear · Slovek | What is the legally provable loss, separate from benefit and reimbursement accounting? |
| Guide 20 · Wrongful Death / Survival | Nicola | Which claim belongs to whom, and what independent deadline applies? |
| Guide 22 · Settlement / Release | Bunnett · Yaekle · Artery · Lauric | What bargain formed, which rights disappear, and which first-party rights must remain? |
Official update sources
Use these sources to check whether a case card or related guide needs revision.
Colorado Supreme Court OpinionsCurrent Supreme Court opinions and 2026 decisions.
Colorado Court of Appeals OpinionsPublished appellate opinions, modifications, and current releases.
2026 Colorado Revised StatutesCurrent statutory text through the 2026 regular session.
VictimsGuide Colorado LibraryReturn from authority to the 23-guide public explanation and workflow.
Frequently asked questions
No. The status badge matters. Colorado Supreme Court decisions are controlling on Colorado-law questions; published Court of Appeals decisions are precedential but can conflict; federal decisions applying Colorado law are predictive or persuasive on state-law meaning; a current-watch case may still be under review.
Because the public page uses a publication gate. A candidate stays in the research queue until the exact citation, source, holding, later history, and current relevance are verified.
No. Weatherill expressly declined to follow Reynolds, creating a published division conflict. One Colorado Court of Appeals division does not formally overrule another. Supreme Court review or legislation can resolve the conflict authoritatively.
Not by itself. The operative published decision remains part of the law unless later court action changes it. A petition is advocacy requesting review, not a merits holding.
Because one case can answer more than one doctrinal question. Fisher concerns a UIM benefit and also defines the statutory consequence of unreasonably withholding an undisputed covered portion while other damages remain disputed.
The Supreme Court’s 2018 Schultz decision is centrally about evaluating bad-faith conduct from the evidence available to the insurer at the time of its decision and about discovery designed to create later evidence. Pinto in 2026 clarifies that Schultz does not impose the same discovery limit on a separate breach-of-contract claim.
No. Use the summary to find the issue and authority, then cite the actual opinion, statute, rule, or policy provision in the form required by the tribunal.
Whenever a cited case receives Supreme Court review, a relevant statute changes, a new published opinion materially affects one of Guides 01–22, or an internal research-queue case clears the publication gate.
← Guide 22Settlement, Release & Claim Closure
Colorado LibraryReturn to the Colorado state overview and complete guide index.
The authority library is the quality-control layer for the entire Colorado series.
Start with the factual issue. Find the current Colorado statute. Read the actual insurance contract. Locate the controlling Supreme Court authority and relevant published appellate cases. Check later history and current review status. Then return to the public guide and confirm that the explanation still reflects the law that governs today.
Public-interest education only. No legal services offered or accepted. No attorney-client relationship created.
Migration source: https://www.victimsguide.com/co-case-authority-library. Verify current Colorado law and official authority before reliance.
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