lien claim (Colorado) · Go Syfert
← Colorado issues

lien claim in Colorado

24 Colorado opinions name it 2 courts 1913–2025 2 in the last five years

The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Gee v. Crabtreegreen
colo · 1977 · cited in 5 Colorado opinions naming this issue, 2002–2017
2 sentences

2017See C.R.C.P. 64(a) (defining judgment as a “decree and order to or from which an appeal lies”); Gee v. Crabtree, 192 Colo. 550 , 560 P.2d 835, 836 (1977) (treating a dissolution decree as a judgment for purposes of section 12-5-119, and holding that an attorney may enforce his charging lien in either the dissolution action that gave rise to the lien claim or an independent action).

2017See C.R.C.P. 64(a) (defining judgment as a “decree and order to or from which an appeal lies”); Gee v. Crabtree, 192 Colo. 550 , 560 P.2d 835, 836 (1977) (treating a dissolution decree as a judgment for purposes of section 12-5-119, and holding that an attorney may enforce his charging lien in either the dissolution action that gave rise to the lien claim or an independent action).

25
People v. Colliegreen
coloctapp · 1983 · cited in 2 Colorado opinions naming this issue, 2007–2008
2 sentences

2008Id.; see People v. Collie, 682 P.2d 1208, 1210 (Colo.App.1988) (noting that the purpose of the Trust Fund Statute "is to protect homeowners, laborers, and materialmen from dishonest or profligate contractors") (emphasis added), First Commercial Corp., 572 F.Supp. at 1484 (noting that the statute creates a separate form of protection because any other interpretation would render either lien claims or trust fund claims superfluous)..

2007Id.; see People v. Collie, 682 P.2d 1208, 1210 (Colo. App.1983) (noting that the purpose of the Trust Fund Statute "is to protect homeowners, laborers, and materialmen from dishonest or profligate contractors ") (emphasis added); First Commercial Corp., 572 F.Supp. at 1434 (noting that the statute creates a separate form of protection because any other interpretation would render either lien claims or trust fund claims superfluous).

22
Buerger Investment Co. v. B. F. Salzer Lumber Co.green
colo · 1925 · cited in 2 Colorado opinions naming this issue, 1990–2005
2 sentences

2005There has been too much of that sort of construction of the Mechanic's Lien Law, and it ought to go no farther." Buerger, 77 Colo. at 407 , 237 P. at 165 . [3] Condominium ownership is recognized and governed by statute in Colorado.

2005There has been too much of that sort of construction of the Mechanic's Lien Law, and it ought to go no farther." Buerger, 77 Colo. at 407 , 237 P. at 165 . [3] Condominium ownership is recognized and governed by statute in Colorado.

12
Mangone v. U-Haul International, Inc.green
coloctapp · 1999 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025Unpreserved Contentions ¶ 13 At the outset, we agree with JP Antlers that to the extent Bobby Hill Designs relies on the first method for establishing a mechanic’s lien claim — section 38-22-101(1) — it failed to preserve this argument. ¶ 14 While we don’t require talismanic language to preserve an issue, In re Estate of Owens, 2017 COA 53, ¶ 21 , we generally won’t address for the first time on appeal issues that weren’t raised before the district court, Mangone v. U-Haul Int’l, Inc., 7 P.3d 189, 191 (Colo. App. 1999).

11
Seitz v. Seitzgreen
coloctapp · 1973 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025See also Seitz v. Seitz, 516 P.2d 654, 655 (Colo. App. 1973) (recognizing that the district court must determine whether an attorney’s lien is valid and whether fees are owed to counsel). ¶8 Wife contends that the district court erred by entering judgment against her because the law firm never provided any evidence in support of the amount of attorney fees and costs that it claimed, and because Basler allegedly violated his professional duties.

11
Jefferson County Board of Equalization v. Gerganoffgreen
colo · 2010 · cited in 1 Colorado opinions naming this issue, 2018–2018
1 sentence

2018See Gerganoff, 241 P.3d at 935 .

11
Jacobsen v. Olivergreen
dcd · 2008 · cited in 1 Colorado opinions naming this issue, 2010–2010
1 sentence

2010See, e.g., Jacobsen, 555 F.Supp.2d at 84 .

11
People v. Benítezgreen
prsupreme · 1915 · cited in 1 Colorado opinions naming this issue, 2007–2007
1 sentence

2007See Williams v. Uncompahgre Canal Co., 13 Colo. 469 , 22 P. 806 (1889).

11
Williams v. Uncompahgre Canal Co.green
colo · 1889 · cited in 1 Colorado opinions naming this issue, 2007–2007
1 sentence

2007See Williams v. Uncompahgre Canal Co., 13 Colo. 469 , 22 P. 806 (1889).

11
First Commercial Corp. v. First National Bancorporation, Inc.green
cod · 1983 · cited in 1 Colorado opinions naming this issue, 2007–2007
2 sentences

2007Id.; see People v. Collie, 682 P.2d 1208, 1210 (Colo.App.1983) (noting that the purpose of the Trust Fund Statute “is to protect home-otvners, laborers, and materialmen from dishonest or profligate contractors ”) (emphasis added); First Commercial Corp., 572 F.Supp. at 1434 (noting that the statute creates a separate form of protection because any other interpretation would render either lien claims or trust fund claims superfluous).

2007Id.; see People v. Collie, 682 P.2d 1208, 1210 (Colo. App.1983) (noting that the purpose of the Trust Fund Statute "is to protect homeowners, laborers, and materialmen from dishonest or profligate contractors ") (emphasis added); First Commercial Corp., 572 F.Supp. at 1434 (noting that the statute creates a separate form of protection because any other interpretation would render either lien claims or trust fund claims superfluous).

11
Schneider v. J.W. Metz Lumber Co.green
colo · 1986 · cited in 1 Colorado opinions naming this issue, 2005–2005
2 sentences

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) (“Colorado courts have long held that the mechanics’ lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien.”); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) (“The mechanics’ lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien.”), rev’d on other grounds, 2 Because a mechanics’ lien is a creature of statute, see ITC, 79

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) ("Colorado courts have long held that the mechanics' lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien."); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) ("The mechanics' lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien."), rev'd on other grounds. [2] Because a mechanics' lien is a creature of statute, see ITC,

11
Brannan Sand & Gravel Co. v. Federal Deposit Insurance Corp.green
coloctapp · 1996 · cited in 1 Colorado opinions naming this issue, 2005–2005
2 sentences

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) (“Colorado courts have long held that the mechanics’ lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien.”); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) (“The mechanics’ lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien.”), rev’d on other grounds, 2 Because a mechanics’ lien is a creature of statute, see ITC, 79

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) ("Colorado courts have long held that the mechanics' lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien."); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) ("The mechanics' lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien."), rev'd on other grounds. [2] Because a mechanics' lien is a creature of statute, see ITC,

11
United States v. Sayresgreen
nywd · 1984 · cited in 1 Colorado opinions naming this issue, 1989–1989
11
Johnson v. Smithgreen
colo · 1984 · cited in 1 Colorado opinions naming this issue, 1985–1985
11
Great Western Sugar Co. v. Jackson Lake Reservoir & Irrigation Co.green
colo · 1984 · cited in 1 Colorado opinions naming this issue, 1985–1985
11
State v. Nelsongreen
tenn · 1953 · cited in 1 Colorado opinions naming this issue, 1969–1969
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway.

Also cited on this issue (29)

CaseCitedYears
Orcasitas v. Registrar of Property neutral
prsupreme · 1907
2 sentences

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

21913–1913
Jensen v. Brown neutral
colo · 1875
2 sentences

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

21913–1913
Tabor v. Armstrong neutral
colo · 1886
2 sentences

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

21913–1913
McIntire v. Barnes neutral
colo · 1878
2 sentences

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

21913–1913
Epley v. Scherer neutral
· 1881
2 sentences

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

1913Prior to the act of 1889 the sub-contractor was required to give notice of an intention to claim a lien with no exception as to amount of the contract, the contract was not required to be in writing or to be filed, and he could not maintain a lien unless at the date of his notice of lien or of his intention to file the same, “there was something due or to become due from the owner to the. contractor.” — Jensen v. Brown, 2 Colo., 694 (Law of 1872); McIntyre v. Barnes, 4 Colo., 285 (Law of 1872); Epley v. Sherrer, 5 Colo., 536 (Law of 1876); Tabor v. Armstrong, 9 Colo., 285 , 12 Pac., 157 (Gener

21913–1913
In Re the Marriage of Mitchell green
coloctapp · 2002
1 sentence

2025A lien may be enforced and reduced to a judgment in a “proper civil action,” § 13-93-114, which “has been held to include . . . filing a motion to reduce the lien to judgment in the civil action that gave rise to the lien claim,” Mitchell, 55 P.3d at 185 .

12025–2025
In re Estate of Owens green
coloctapp · 2017
1 sentence

2025Unpreserved Contentions ¶ 13 At the outset, we agree with JP Antlers that to the extent Bobby Hill Designs relies on the first method for establishing a mechanic’s lien claim — section 38-22-101(1) — it failed to preserve this argument. ¶ 14 While we don’t require talismanic language to preserve an issue, In re Estate of Owens, 2017 COA 53, ¶ 21 , we generally won’t address for the first time on appeal issues that weren’t raised before the district court, Mangone v. U-Haul Int’l, Inc., 7 P.3d 189, 191 (Colo. App. 1999).

12025–2025
Fowler & Peth, Inc. v. Regan green
colo · 2007
1 sentence

2008The trial court disagreed, relying upon In re Regan, 151 P.3d 1281 (Colo.2007), to find that "as benefi-claries, property owners are able to enforce the Trust Fund Statute against the contractor separate from the lien claim laws." On appeal, Pullen argues that the court's reliance on Regan is misplaced and the court's ruling erroneously allows homeowners the right to sue when such right under the statute should only be given to subcontractors, laborers, and material suppliers.

12008–2008
Discount Home Center, Inc. v. Turner (In Re Turner) green
oknb · 1991
2 sentences

2007The court in In re Turner held that even when a lien creditor fails to perfect a lien, the contractor-trustee may not breach his own fiduciary duty to hold trust funds so that no liens need be created at all. 134 B.R. at 656-57 .

2007The court in In re Turner held that even when a lien creditor fails to perfect a lien, the contractor-trustee may not breach his own fiduciary duty to hold trust funds so that no liens need be created at all. 134 B.R. at 656-57 .

12007–2007
Damrell v. Creagar green
coloctapp · 1979
2 sentences

2007Damrell v. Creagar, 42 Colo.App. 281 , 599 P.2d 262 (1979).

2007Damrell v. Creagar, 42 Colo.App. 281 , 599 P.2d 262 (1979).

12007–2007
Woodcrest Homes, Inc. v. First National Bank of Pueblo (In re Woodcrest Homes, Inc.) neutral
cod · 1981
1 sentence

2005In re Woodcrest Homes, Inc., 11 B.R. 342 (Bankr.D.Colo.), aff'd in part and rev'd in part, 15 B.R. 886 (D.Colo.1981).

12005–2005
Woodcrest Homes, Inc. v. First National Bank of Pueblo (In Re Woodcrest Homes, Inc.) green
cob · 1981
1 sentence

2005In re Woodcrest Homes, Inc., 11 B.R. 342 (Bankr.D.Colo.), aff'd in part and rev'd in part, 15 B.R. 886 (D.Colo.1981).

12005–2005
Independent Trust Corp. v. Stan Miller, Inc. green
colo · 1990
2 sentences

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) (“Colorado courts have long held that the mechanics’ lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien.”); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) (“The mechanics’ lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien.”), rev’d on other grounds, 2 Because a mechanics’ lien is a creature of statute, see ITC, 79

2005Metz Lumber Co., 715 P.2d 329, 332 (Colo.1986) ("Colorado courts have long held that the mechanics' lien statute [is in] derogation of the common law [and] is to be strictly construed in determining who is entitled to a lien."); Brannan Sand & Gravel Co. v. F.D.I.C., 928 P.2d 1337, 1342 (Colo.App.1996) ("The mechanics' lien statute is to be strictly construed with respect to those acts necessary to perfect the lien and liberally construed with respect to the benefits accorded a properly perfected lien."), rev'd on other grounds. [2] Because a mechanics' lien is a creature of statute, see ITC,

12005–2005
Adler v. Fenton green
scotus · 1861
2 sentences

2003Adler v. Fenton, 65 U.S. (24 How.) 407 , 16 L.Ed. 696 (1860); see also Pullen v. Headberg, supra. However, modern fraudulent transfer law, like CUFTA, has dispensed with the lien requirement, focusing instead on the debtor’s intent to frustrate the creditor once its claim is made known.

2003Adler v. Fenton, 65 U.S. (24 How.) 407 , 16 L.Ed. 696 (1860); see also Pullen v. Headberg, supra. However, modern fraudulent transfer law, like CUFTA, has dispensed with the lien requirement, focusing instead on the debtor’s intent to frustrate the creditor once its claim is made known.

12003–2003
Aleman v. Annable green
colo · 1942
2 sentences

1990Aleman v. Annable, 110 Colo. 61 , 129 P.2d 987 (1942); Nichols v. Orr, 63 Colo. 333 , 166 P. 561 (1917); Cottonwood Hill, Inc. v. Ansay, 782 P.2d 1207 (Colo. App.1989).

1990Aleman v. Annable, 110 Colo. 61 , 129 P.2d 987 (1942); Nichols v. Orr, 63 Colo. 333 , 166 P. 561 (1917); Cottonwood Hill, Inc. v. Ansay, 782 P.2d 1207 (Colo. App.1989).

11990–1990
Collins v. Thuringer green
colo · 1933
2 sentences

1990In Collins v. Thuringer, 92 Colo. 433 , 21 P.2d 709 (1933), our supreme court determined that one who garnished a judgment debtor to secure funds owed to him by a judgment creditor did not have priority over the lien of the attorney for the judgment creditor.

1990In Collins v. Thuringer, 92 Colo. 433 , 21 P.2d 709 (1933), our supreme court determined that one who garnished a judgment debtor to secure funds owed to him by a judgment creditor did not have priority over the lien of the attorney for the judgment creditor.

11990–1990
Cottonwood Hill, Inc. v. Ansay green
coloctapp · 1989
11990–1990
Nichols v. Orr green
colo · 1917
11990–1990
Stan Miller, Inc. v. Breckenridge Resort Associates, Inc. green
coloctapp · 1989
11990–1990
BOARD OF CTY. COM'RS, ETC. v. Berkeley Village green
coloctapp · 1978
11990–1990
West Alexandria Properties, Inc. v. First Virginia Mortgage & Real Estate Investment Trust green
va · 1980
2 sentences

1990West Alexandria Properties, Inc. v. First Virginia Mortgage and Real Estate Investment Trust, 221 Va. 134 , 267 S.E.2d 149 (1980) and PIC Construction Co. v. First Union National Bank of North Carolina, 218 Va. 915 , 241 S.E.2d 804 (1978) dealt with the partial release of a mechanics’ lien claim and the subsequent attempt by the claimant to enforce the lien against the remainder of the property.

1990West Alexandria Properties, Inc. v. First Virginia Mortgage and Real Estate Investment Trust, 221 Va. 134 , 267 S.E.2d 149 (1980) and PIC Construction Co. v. First Union National Bank of North Carolina, 218 Va. 915 , 241 S.E.2d 804 (1978) dealt with the partial release of a mechanics’ lien claim and the subsequent attempt by the claimant to enforce the lien against the remainder of the property.

11990–1990
PIC Construction Co. v. First Union National Bank of North Carolina green
va · 1978
2 sentences

1990West Alexandria Properties, Inc. v. First Virginia Mortgage and Real Estate Investment Trust, 221 Va. 134 , 267 S.E.2d 149 (1980) and PIC Construction Co. v. First Union National Bank of North Carolina, 218 Va. 915 , 241 S.E.2d 804 (1978) dealt with the partial release of a mechanics’ lien claim and the subsequent attempt by the claimant to enforce the lien against the remainder of the property.

1990West Alexandria Properties, Inc. v. First Virginia Mortgage and Real Estate Investment Trust, 221 Va. 134 , 267 S.E.2d 149 (1980) and PIC Construction Co. v. First Union National Bank of North Carolina, 218 Va. 915 , 241 S.E.2d 804 (1978) dealt with the partial release of a mechanics’ lien claim and the subsequent attempt by the claimant to enforce the lien against the remainder of the property.

11990–1990
The Superior Oil Company v. The City of Port Arthur green
ca5 · 1984
11989–1989
United States, Small Business Administration v. Freeland (In Re Chaseley's Foods, Inc.) green
innd · 1983
11989–1989
Hutchison v. Bank of North Carolina green
ncmd · 1975
11977–1977
Terranova v. Avco Financial Services of Barre, Inc. green
vtd · 1975
11977–1977
Davidson v. Board of County Commissioners green
colo · 1899
11933–1933
Clarke v. Day neutral
nj · 1905
11916–1916
In re Stowell neutral
nynd · 1885
11916–1916

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 38-22-101 (7) CO § Colo. Rev. Stat. § 38-22-110 (4) CO § Colo. Rev. Stat. § 2-4-201 (3) CO § Colo. Rev. Stat. § 38-22-103 (3) CO § Colo. Rev. Stat. § 38-22-106 (3) CO § Colo. Rev. Stat. § 38-22-109 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

LA 128 (1899–2025) IL 126 (1882–2025) CA 96 (1868–2026) PA 94 (1858–2025) MO 53 (1881–2019) NJ 47 (1874–2024) NY 46 (1887–2025) WA 45 (1892–2025) TX 42 (1917–2024) FL 38 (1909–2025) MD 35 (1911–2021) MN 34 (1890–2016) OK 34 (1910–2021) OR 29 (1892–2023) CO 24 (1913–2025) GA 23 (1878–2025) AL 22 (1894–2018) WI 22 (1873–2022) NV 18 (1914–2020) UT 18 (1909–2025) ID 17 (1915–2024) NC 13 (1964–2024) CT 13 (1980–2017) IN 13 (1879–2015) ME 12 (1955–2018) AZ 12 (1968–2012) MI 11 (1934–2022) SD 10 (1911–2025) MT 9 (1919–2019) VA 9 (1966–2010) WY 8 (1940–2007) IA 8 (1961–2021) NM 7 (1931–2020) OH 7 (1894–2022) AR 6 (1905–2014) KY 6 (1869–2017) SC 4 (1997–2014) ND 4 (1952–1998) KS 4 (1938–2022) MA 3 (1973–2011) WV 3 (1911–1948) RI 3 (1991–1998) DE 3 (1938–2017) NE 3 (1897–1992) MS 3 (1924–2014) AK 2 (1977–1981) DC 2 (1979–1991) TN 2 (1944–1977)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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