Williams factors (Colorado) · Go Syfert
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Williams factors in Colorado

9 Colorado opinions name it 2 courts 1994–2026 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 (8)

CaseFollowedCited
Williams v. District Court, El Paso Countygreen
colo · 1985 · cited in 3 Colorado opinions naming this issue, 1994–2001
2 sentences

2001Id. at 558 (stating that, when it was unclear that the attorney's testimony would be necessary under the third prong of the Williams test, to "require [the attorney] to make himself available as a possible witness for the prosecution would be' tantamount to unnecessarily terminating the lawyer-client relationship ... a result that offers no countervailing benefits to the administration of justice and could seriously disadvantage the petitioner").

2001Id. at 558 (stating that, when it was unclear that the attorney's testimony would be necessary under the third prong of the Williams test, to "require [the attorney] to make himself available as a possible witness for the prosecution would be' tantamount to unnecessarily terminating the lawyer-client relationship ... a result that offers no countervailing benefits to the administration of justice and could seriously disadvantage the petitioner").

23
Zivian v. Brooke-Hitchinggreen
coloctapp · 2001 · cited in 1 Colorado opinions naming this issue, 2026–2026
1 sentence

2026See Zivian v. Brooke-Hitching, 28 P.3d 970, 974 (Colo. App. 2001).

11
Cruz v. Beninegreen
colo · 1999 · cited in 1 Colorado opinions naming this issue, 2026–2026
1 sentence

2026A vexatious claim or defense is one brought or maintained in bad faith, which includes conduct that is arbitrary, abusive, stubbornly litigious, aimed at unwarranted delay, or disrespectful of truth and 4 We reject the Williams defendants’ argument that Wyles’s attorney’s “failure to preserve his own appeal, by either filing his own separate appeal or being added as an appellant, renders final the judgment against him.” See Cruz v. Benine, 984 P.2d 1173, 1181 (Colo. 1999) (reversing dismissal of appeal of attorney fees award against attorney that was entered jointly and severally against attor

11
People v. Cordovagreen
coloctapp · 2007 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025See People v. Cordova, 199 P.3d 1, 4 (Colo. App. 2007). ¶9 Accordingly, we agree with the People that Williams’ motion for proportionality review is untimely under section 16-5-402(1).

11
Renteria v. Colorado State Department of Personnelgreen
colo · 1991 · cited in 1 Colorado opinions naming this issue, 2015–2015
1 sentence

2015But the Board points out-and CSP does not dispute-that this time "does not run if the notice did not properly advise the employee of his or her right to appeal." Renteria v. Colo. State Dep't of Pers., 811 P.2d 797 802 (Colo.1991); see also Cunningham, 823 P.2d at 1380. 141 CSP's letter notifying Williams that he would not be reinstated failed to explain Williams' right to appeal to the Director, Thus, we remand Williams' claim CSP acted arbitrarily or capriciously to the Board for referral to the Director, who may consider whether the claim has been tolled by lack of notice.

11
People v. Pereagreen
coloctapp · 2005 · cited in 1 Colorado opinions naming this issue, 2012–2012
1 sentence

2012See People v. Perea, 126 P.3d 241, 246 (Colo.App.2005) (affirming denial of a mistrial for testimony about the defendant's marijuana smoking, in light of similar uncontested and admissible evidence). { 24 We conclude that the trial court did not abuse its discretion by denying Williams' motion for a mistrial.

11
People v. Rosenthalgreen
coloctapp · 1983 · cited in 1 Colorado opinions naming this issue, 2008–2008
1 sentence

2008See People v. Rosenthal, 670 P.2d 1254, 1256 (Colo.App.1983) (“the trial court must rule that the privilege is available” before the declarant is deemed unavailable).

11
Riley v. District Court in & for Second Judicial Dist.green
colo · 1973 · cited in 1 Colorado opinions naming this issue, 1995–1995
2 sentences

1995“It is obvious that a lawyer cannot act as an advocate on behalf of his client, and yet give testimony adverse to the interests of that client in the same proceeding.” Id. at 555 (quoting Riley v. District Court, 181 Colo. 90, 95 , 507 P.2d 464, 466 (1973)). 1 We specifically held that when opposing counsel is subpoenaed, a trial court should consider that act as “the functional equivalent of a motion to disqualify.” Accordingly, the trial court should have considered the subpoena as a motion to disqualify and determined whether any conflict requiring disqualification was involved. 2 The trial

1995“It is obvious that a lawyer cannot act as an advocate on behalf of his client, and yet give testimony adverse to the interests of that client in the same proceeding.” Id. at 555 (quoting Riley v. District Court, 181 Colo. 90, 95 , 507 P.2d 464, 466 (1973)). 1 We specifically held that when opposing counsel is subpoenaed, a trial court should consider that act as “the functional equivalent of a motion to disqualify.” Accordingly, the trial court should have considered the subpoena as a motion to disqualify and determined whether any conflict requiring disqualification was involved. 2 The trial

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 (4)

CaseCitedYears
Fitzsimmons v. Olinger Mortuary Ass'n green
colo · 1932
2 sentences

2003In our Williams analysis, we explained the context of the legislature’s silence, finding that “[c]ase law existed in 1973 to guide the General Assembly in limiting common-law remedies against insurance companies if that result was intended.” Id. at 425 (citing Fitzsimmons v. Olinger Mortuary Ass’n, 91 Colo. 544 , 17 P.2d 535 (1932) (a common law contract case allowing non-economic mental suffering damages for a willful-and-wanton breach)).

2003In our Williams analysis, we explained the context of the legislature’s silence, finding that “[c]ase law existed in 1973 to guide the General Assembly in limiting common-law remedies against insurance companies if that result was intended.” Id. at 425 (citing Fitzsimmons v. Olinger Mortuary Ass’n, 91 Colo. 544 , 17 P.2d 535 (1932) (a common law contract case allowing non-economic mental suffering damages for a willful-and-wanton breach)).

12003–2003
Farmers Group, Inc. v. Williams green
colo · 1991
1 sentence

2003In our Williams analysis, we explained the context of the legislature’s silence, finding that “[c]ase law existed in 1973 to guide the General Assembly in limiting common-law remedies against insurance companies if that result was intended.” Id. at 425 (citing Fitzsimmons v. Olinger Mortuary Ass’n, 91 Colo. 544 , 17 P.2d 535 (1932) (a common law contract case allowing non-economic mental suffering damages for a willful-and-wanton breach)).

12003–2003
Taylor v. Grogan green
colo · 1995
2 sentences

2001In a subsequent case, Taylor v. Grogan, 900 P.2d 60 , 62 n. 5 (Colo.1995), we extended the Williams test to civil cases.

2001In a subsequent case, Taylor v. Grogan, 900 P.2d 60 , 62 n. 5 (Colo.1995), we extended the Williams test to civil cases.

12001–2001
Grogan v. Taylor green
coloctapp · 1994
2 sentences

1995Grogan, 877 P.2d at 1382 .

1995Grogan, 877 P.2d at 1382 .

11995–1995

Where else courts name it

FL 418 (1933–2026) CA 142 (1959–2026) GA 133 (1981–2026) TX 104 (1970–2025) IL 88 (1988–2026) CT 88 (2003–2025) OH 85 (1997–2026) PA 76 (1948–2026) MS 54 (1990–2024) AL 38 (1985–2025) WA 38 (1980–2026) IN 36 (1894–2023) VA 24 (1987–2026) MO 23 (1973–2025) LA 19 (1983–2025) NE 17 (1983–2024) TN 17 (1981–2026) AZ 17 (1985–2025) WI 17 (1998–2025) KS 16 (1983–2024) MD 15 (1975–2022) DC 14 (1977–2024) MN 14 (1967–2025) SC 13 (2015–2025) MI 13 (1966–2020) AR 13 (1974–2024) MT 13 (1973–2017) DE 12 (1970–2026) NC 12 (1983–2025) NY 11 (1974–2026) NM 10 (1976–2024) NJ 10 (1967–2022) AK 10 (1983–2023) CO 9 (1994–2026) UT 8 (1999–2019) ME 8 (2001–2024) MA 7 (1981–2013) NV 7 (1983–2021) ID 7 (1974–2018) OK 7 (1987–2018) WY 6 (1980–2026) ND 6 (1987–2025) WV 5 (1980–2017) IA 4 (1996–2020) NH 3 (1998–2011) HI 3 (2007–2020) VI 2 (2011–2016) VT 2 (1985–2019) KY 2 (2020–2023) SD 2 (2006–2008)

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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