payment doctrine (Colorado) · Go Syfert
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payment doctrine in Colorado

13 Colorado opinions name it 2 courts 1885–2014 0 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 (17)

CaseFollowedCited
Dodge v. Eastgreen
colo · 1937 · cited in 1 Colorado opinions naming this issue, 2014–2014
2 sentences

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

11
Lieske v. Swangreen
colo · 1933 · cited in 1 Colorado opinions naming this issue, 2014–2014
2 sentences

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

11
Vessels v. Hickersongreen
coloctapp · 2012 · cited in 1 Colorado opinions naming this issue, 2014–2014
2 sentences

2014It reasoned that the separation of powers doe-trine precludes a common law doctrine that operates to shorten a legislatively prescribed limitations period: "In deference to the separation of powers doctrine, we are wary of invoking an equitable principle, such as lach-es, where the legislative branch of government has already made a clear policy judgment." - Vessels, — P.3d at —, 2012 WL 503664 , at *15 18 We granted Hickerson's petition for review.

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

11
Buckingham v. Orrgreen
colo · 1883 · cited in 1 Colorado opinions naming this issue, 2014–2014
2 sentences

2014The Partial Payment Doctrine Does Not Preclude a Laches Defense 119 The partial payment doctrine has been part of our common law jurisprudence since at least 1883 when we decided Buckingham v. Orr, 6 Colo. 587, 589-90 (Colo.1883).

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

11
Shell Western E&P, Inc. v. Dolores County Board of Commissionersgreen
colo · 1997 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See Shell, 948 P.2d at 1007 (court may apply equitable tolling principles where a defendant fails to provide statutorily imposed notice to plaintiff). [57 Hickerson argues that In re Estate of Ongaro, 973 P.2d 660 (Colo.App.1998), aff'd, 998 P.2d 1097 (Colo.2000), supports the proposition that the partial payment doctrine is a creature of equitable tolling.

11
Drake v. Tynergreen
coloctapp · 1996 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See id.

11
Hill v. DeWittgreen
colo · 2002 · cited in 1 Colorado opinions naming this issue, 2012–2012
2 sentences

2012See In re Estate of Becker, 32 P.3d 557, 563 (Colo.App.2000) (one division of the court of appeals is not obligated to follow decisions of another division), aff'd, 54 P.3d 849 (Colo.2002).

2012See In re Estate of Becker, 32 P.3d 557, 563 (Colo.App.2000) (one division of the court of appeals is not obligated to follow decisions of another division), aff'd, 54 P.3d 849 (Colo.2002).

11
Denver Water Department Credit Union v. Estate of Ongarogreen
colo · 2000 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See Shell, 948 P.2d at 1007 (court may apply equitable tolling principles where a defendant fails to provide statutorily imposed notice to plaintiff). [57 Hickerson argues that In re Estate of Ongaro, 973 P.2d 660 (Colo.App.1998), aff'd, 998 P.2d 1097 (Colo.2000), supports the proposition that the partial payment doctrine is a creature of equitable tolling.

11
Berger v. Coongreen
colo · 1980 · cited in 1 Colorado opinions naming this issue, 2012–2012
2 sentences

2012Beathune, 30 Colo.App. at 326 , 494 P.2d at 605 ; Pasternak, 511 P.2d at 530-31; see also Coon v. Berger, 41 Colo.App. 358 , 360, 588 P.2d 386, 387-88 (1978) (discussion not necessary for the decision before the court is dicta and not controlling on later decisions), aff'd, 199 Colo. 133 , 606 P.2d 68 (1980). 162 Accordingly, we conclude, under the cireumstances here, that the trial court erred in ruling that laches was available as a defense to Vessels's timely filed claim brought to recover on a promissory note, where a new statute of limitations period was triggered, as a matter of law, by

2012Beathune, 30 Colo.App. at 326 , 494 P.2d at 605 ; Pasternak, 511 P.2d at 530-31; see also Coon v. Berger, 41 Colo.App. 358 , 360, 588 P.2d 386, 387-88 (1978) (discussion not necessary for the decision before the court is dicta and not controlling on later decisions), aff'd, 199 Colo. 133 , 606 P.2d 68 (1980). 162 Accordingly, we conclude, under the cireumstances here, that the trial court erred in ruling that laches was available as a defense to Vessels's timely filed claim brought to recover on a promissory note, where a new statute of limitations period was triggered, as a matter of law, by

11
Coon v. Bergergreen
coloctapp · 1978 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012Beathune, 30 Colo.App. at 326 , 494 P.2d at 605 ; Pasternak, 511 P.2d at 530-31; see also Coon v. Berger, 41 Colo.App. 358 , 360, 588 P.2d 386, 387-88 (1978) (discussion not necessary for the decision before the court is dicta and not controlling on later decisions), aff'd, 199 Colo. 133 , 606 P.2d 68 (1980). 162 Accordingly, we conclude, under the cireumstances here, that the trial court erred in ruling that laches was available as a defense to Vessels's timely filed claim brought to recover on a promissory note, where a new statute of limitations period was triggered, as a matter of law, by

11
In Re Estate of Beckergreen
coloctapp · 2001 · cited in 1 Colorado opinions naming this issue, 2012–2012
2 sentences

2012See In re Estate of Becker, 32 P.3d 557, 563 (Colo.App.2000) (one division of the court of appeals is not obligated to follow decisions of another division), aff'd, 54 P.3d 849 (Colo.2002).

2012See In re Estate of Becker, 32 P.3d 557, 563 (Colo.App.2000) (one division of the court of appeals is not obligated to follow decisions of another division), aff'd, 54 P.3d 849 (Colo.2002).

11
Lyons Partnership, L.P., a Texas Limited Partnership v. Morris Costumes, Incorporated Philip Morris Amy Morris Smithgreen
ca4 · 2001 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See Lyons P'ship, L.P., 243 F.3d at 798 ("Separation of powers principles thus preclude us from applying the judicially created doctrine of lach-es to bar a federal statutory claim that has been timely filed under an express statute of limitations."); Ivani Contracting Corp., 103 F.3d at 260 ; see also Chirco, 474 F.3d at 235 (refusing to apply laches to the plaintiffs' claims for monetary relief and prospective injunctive relief because "under our tripartite system of government, [the wisdom of a three-year statute of limitations for copyright infringement] is committed to the discretion of t

11
Michael A. Chirco Dominic J. Moceri v. Crosswinds Communities, Inc., and Bernard Gliebermangreen
ca6 · 2007 · cited in 1 Colorado opinions naming this issue, 2012–2012
2 sentences

2012Chirco, 474 F.3d at 2209-31 ; Teamsters & Emp'rs, 283 F.3d at 879-81 .

2012See Lyons P'ship, L.P., 243 F.3d at 798 ("Separation of powers principles thus preclude us from applying the judicially created doctrine of lach-es to bar a federal statutory claim that has been timely filed under an express statute of limitations."); Ivani Contracting Corp., 103 F.3d at 260 ; see also Chirco, 474 F.3d at 235 (refusing to apply laches to the plaintiffs' claims for monetary relief and prospective injunctive relief because "under our tripartite system of government, [the wisdom of a three-year statute of limitations for copyright infringement] is committed to the discretion of t

11
Denver Water Department Credit Union v. Estate of Ongarogreen
coloctapp · 1999 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See Shell, 948 P.2d at 1007 (court may apply equitable tolling principles where a defendant fails to provide statutorily imposed notice to plaintiff). [57 Hickerson argues that In re Estate of Ongaro, 973 P.2d 660 (Colo.App.1998), aff'd, 998 P.2d 1097 (Colo.2000), supports the proposition that the partial payment doctrine is a creature of equitable tolling.

11
Cates v. Continental Casualty Co.green
texapp · 1963 · cited in 1 Colorado opinions naming this issue, 2002–2002
1 sentence

2002Co., 366 S.W.2d 126, 127 (Tex.Ct.Civ.App.1963) ("[Nlo issue of fact is raised by appellant's affidavit that he 'believed said check to be either a partial payment of claim or dividend." ").

11
Koch v. Construction Technology, Inc.green
tenn · 1996 · cited in 1 Colorado opinions naming this issue, 1999–1999
1 sentence

1999See Koch v. Construction Tech., Inc., 924 S.W.2d 68 , 71 & n. 1 (Tenn.1996) (reviewing cases). 7 .

11
Farshawe v. Lanegreen
nysupct · 1862 · cited in 1 Colorado opinions naming this issue, 1885–1885
1 sentence

1885See Fanshawe v. Lane, 16 Abb.

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 (12)

CaseCitedYears
United States v. County of MacOn green
scotus · 1879
2 sentences

1901In United States v. Macon, 99 U. S. 582 , it was sought to compel the authorities of the county of Macon, Missouri, to levy a tax for the payment of a judgment recovered by the relator against the county upon interest coupons detached from bonds issued by it under an act of the general assembly of the state incorporating the Mississippi and Missouri Railroad Company.

1901In United States v. Macon, 99 U. S. 582 , it was sought to compel the authorities of the county of Macon, Missouri, to levy a tax for the payment of a judgment recovered by the relator against the county upon interest coupons detached from bonds issued by it under an act of the general assembly of the state incorporating the Mississippi and Missouri Railroad Company.

21901–1901
Holmquist v. Gilbert green
colo · 1907
1 sentence

2014Buckingham, 6 Colo. at 589-90 ; Dodge v. East, 100 Colo. 36 , 64 P.2d 1270, 1271 (1937) ("[Vloluntary payments made by the debtor [interrupt] the operation of the statute of limitations."); Holmquist v. Gilbert, 41 Colo. 113 , 92 P. 232 , 233 (1907) (holding that the partial payment by a trustee does not revive a debt outside the statute of limitations where the trustee was an agent of both the creditor and debtor). 120 While the court of appeals recognized that the partial payment doctrine is a part of our common law, it determined that restarting the limitations period thereunder necessarily

12014–2014
Ivani Contracting Corporation v. The City Of New York green
ca2 · 1997
1 sentence

2012See Lyons P'ship, L.P., 243 F.3d at 798 ("Separation of powers principles thus preclude us from applying the judicially created doctrine of lach-es to bar a federal statutory claim that has been timely filed under an express statute of limitations."); Ivani Contracting Corp., 103 F.3d at 260 ; see also Chirco, 474 F.3d at 235 (refusing to apply laches to the plaintiffs' claims for monetary relief and prospective injunctive relief because "under our tripartite system of government, [the wisdom of a three-year statute of limitations for copyright infringement] is committed to the discretion of t

12012–2012
Beathune v. Cain green
coloctapp · 1971
2 sentences

2012Beathune, 30 Colo.App. at 326 , 494 P.2d at 605 ; Pasternak, 511 P.2d at 530-31; see also Coon v. Berger, 41 Colo.App. 358 , 360, 588 P.2d 386, 387-88 (1978) (discussion not necessary for the decision before the court is dicta and not controlling on later decisions), aff'd, 199 Colo. 133 , 606 P.2d 68 (1980). 162 Accordingly, we conclude, under the cireumstances here, that the trial court erred in ruling that laches was available as a defense to Vessels's timely filed claim brought to recover on a promissory note, where a new statute of limitations period was triggered, as a matter of law, by

2012Beathune, 30 Colo.App. at 326 , 494 P.2d at 605 ; Pasternak, 511 P.2d at 530-31; see also Coon v. Berger, 41 Colo.App. 358 , 360, 588 P.2d 386, 387-88 (1978) (discussion not necessary for the decision before the court is dicta and not controlling on later decisions), aff'd, 199 Colo. 133 , 606 P.2d 68 (1980). 162 Accordingly, we conclude, under the cireumstances here, that the trial court erred in ruling that laches was available as a defense to Vessels's timely filed claim brought to recover on a promissory note, where a new statute of limitations period was triggered, as a matter of law, by

12012–2012
Teamsters & Employers Welfare Trust of Illinois v. Gorman Brothers Ready Mix green
ca7 · 2002
2 sentences

2012Chirco, 474 F.3d at 2209-31 ; Teamsters & Emp'rs, 283 F.3d at 879-81 .

2012Teamsters & Emp'rs, 283 F.3d at 882-85 . 1155 To the extent that the trial court here interpreted Teamsters to permit a lach-es defense where a court had previously equitably tolled the statute of limitations in the same case, we nevertheless conclude that the trial court erred because, in Colorado, the partial payment doctrine is a judge-made rule of law interpreting the statute of limitations, not a creature of equity.

12012–2012
Payroll Check Cashing v. New Palestine Bank green
indctapp · 1980
1 sentence

2000Finally, there is no claim that Pueblo Bank had actual knowledge of the forged signatures, and thus subsection (a)(3) does not apply. *787 Indeed, as the court noted in Payroll Check Cashing v. New Palestine Bank, 401 N.E.2d 752 (Ind.App.1980), if the warranty that all signatures were genuine applied to a bank in the position of Pueblo Bank, the final payment doctrine contained in § 4-3^18 would be meaningless.

12000–2000
Brandon v. Sterling Colorado Beef Co. green
coloctapp · 1991
1 sentence

1997Brandon v. Sterling Colorado Beef Co., 827 P.2d 559 (Colo.App.1991).

11997–1997
Brighton School District 27J v. Transamerica Premier Insurance Co. green
coloctapp · 1996
2 sentences

1997We granted certiorari to review the court of appeals decision in Brighton School District 27J v. Transamerica Premier Insurance Co., 923 P.2d 328 (Colo.App.1996), to determine whether Colorado recognizes the existence of a common law tort claim against a commercial surety who fails to reasonably proceed with the payment of a claim under a performance bond.

1997We granted certiorari to review the court of appeals decision in Brighton School District 27J v. Transamerica Premier Insurance Co., 923 P.2d 328 (Colo.App.1996), to determine whether Colorado recognizes the existence of a common law tort claim against a commercial surety who fails to reasonably proceed with the payment of a claim under a performance bond.

11997–1997
Barnes v. Spangler green
colo · 1936
2 sentences

1954Barnes v. Spangler, 98 Colo. 407 , 56 P. (2d) 31 .

1954Barnes v. Spangler, 98 Colo. 407 , 56 P. (2d) 31 .

11954–1954
Grotte v. Weil & Co. neutral
neb · 1901
2 sentences

1930Grotte v. Weil, 62 Neb. 478 , 87 N. W. 173 , 9 L.

1930Grotte v. Weil, 62 Neb. 478 , 87 N. W. 173 , 9 L.

11930–1930
In re Appropriations by General Assembly green
· 1889
1 sentence

1893In re Appropriations, 13 Colo. 316 ; Mute & Blind Institute v. Henderson, ante, p. 98; In re Continuing Appropriations, ante p. 192; Burritt v. Commissioners, 120 Ills. 322; May v. Rice, 91 Ind. 546 .

11893–1893
May v. Rice green
ind · 1883
1 sentence

1893In re Appropriations, 13 Colo. 316 ; Mute & Blind Institute v. Henderson, ante, p. 98; In re Continuing Appropriations, ante p. 192; Burritt v. Commissioners, 120 Ills. 322; May v. Rice, 91 Ind. 546 .

11893–1893

Where else courts name it

NY 128 (1848–2026) CA 72 (1860–2026) IL 69 (1885–2024) FL 58 (1922–2024) TX 54 (1873–2023) GA 36 (1895–2017) OR 34 (1897–2024) IN 32 (1875–2023) PA 31 (1842–2022) CT 30 (1913–2025) AL 30 (1856–2011) OH 25 (1886–2024) WA 19 (1901–2017) LA 19 (1855–2021) MI 18 (1898–2025) MD 18 (1847–2025) IA 18 (1873–2004) KS 17 (1889–1981) NJ 17 (1889–2022) KY 16 (1865–2024) AZ 15 (1906–2021) WV 15 (1900–2022) OK 15 (1892–2010) AR 14 (1909–2004) TN 14 (1921–2014) MO 14 (1868–2014) NE 14 (1882–1980) CO 13 (1885–2014) MA 10 (1873–2004) VA 10 (1884–2024) NC 9 (1902–1993) SD 7 (1905–1959) WY 7 (1905–2021) NM 7 (1885–2024) WI 6 (1881–2013) MT 6 (1897–1952) UT 6 (1926–2021) MN 5 (1864–1993) VT 5 (1861–1990) ID 5 (1915–2014) RI 4 (1895–2014) MS 4 (1922–1961) HI 4 (1922–2010) NV 3 (1986–2014) ND 3 (1919–1985) SC 2 (1960–1960) DE 2 (1934–2022) NH 2 (1869–1882)

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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