USAA v. Wenzell: Colorado Supreme Court Clarifies That C.R.S. § 10-3-1118 Failure-to-Cooperate Requirements Do Not Apply to Policy Conditions Precedent

In April 2026, the Colorado Supreme Court clarified C.R.S. § 10-3-1118 did not abrogate the common law distinction between general failure-to-cooperate defenses and defenses based on specific policy conditions precedent.  In USAA v. Wenzell, the Court held (6-1) that only defenses based on an insured’s general common law duty to cooperate, rather than on conditions […]

Colorado Bill Increases Statutory Damage Caps

Colorado House Bill 24-1472, approved on June 3, 2024, increased statutory damage limitations under C.R.S. §§ 13-21-102.5 (noneconomic losses) and 13-21-203.7 (wrongful death). For civil actions filed on or after January 1, 2025, other than medical malpractice suits and those filed against health care workers, the total for noneconomic damages cannot exceed $1,500,000. The previous […]

Ashley Larson and Karlee Janigian Obtain Partial Summary Judgment Limiting Recoverable Damages After Underlying Worker’s Compensation Settlement

Ashley Larson and Karlee Janigian obtained partial summary judgment on behalf of a retail client limiting the damages a plaintiff may pursue at trial in a premises liability case. The ruling narrowed the plaintiff’s trial damages to noneconomic damages and any recoverable portion of lost wages not fully covered by workers’ compensation, limiting the exposure […]