primacy requirement (Colorado) · Go Syfert
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primacy requirement in Colorado

6 Colorado opinions name it 2 courts 1994–2009 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 (4)

CaseFollowedCited
Holter v. Moore and Co.green
coloctapp · 1983 · cited in 2 Colorado opinions naming this issue, 2009–2009
2 sentences

2009No. 07CA2063, Dec. 11, 2008) (refusing to read a primacy requirement into coverage mandated by statute at issue where different statute expressly included such a requirement, thus showing that the General Assembly knew how to identify primary insurance coverage when it intended to do so); Husson v. Meeker, 812 P.2d 781, 738 (Colo.App.1991) (where different section of Workers' Compensation Act expressly provided for prejudgment interest, division would not infer that legislature inadvertently failed to provide for such interest in the statute at issue, because legislature knew how to deal with

2009No. 07CA2063, Dec. 11, 2008) (refusing to read a primacy requirement into coverage mandated by statute at issue where different statute expressly included such a requirement, thus showing that the General Assembly knew how to identify primary insurance coverage when it intended to do so); Husson v. Meeker, 812 P.2d 731, 733 (Colo.App.1991) (where different section of Workers' Compensation Act expressly provided for prejudgment interest, division would not infer that legislature inadvertently failed to provide for such interest in the statute at issue, because legislature knew how to deal with

22
Tate v. Industrial Claim Appeals Officegreen
colo · 1991 · cited in 2 Colorado opinions naming this issue, 1994–2000
2 sentences

2000Pursuant to the primacy rule of the Colorado Auto Accident Reparations Act (the No-Fault Act), the workers’ compensation insurer was required to pay benefits, in lieu of the PIP benefits which would otherwise have been paid by the auto insurer. 4 See id. at 19 .

1994See Tate v. Industrial Claim Appeals Office, supra. In Tate , our supreme court concluded that a workers’ compensation carrier was not entitled to credit for benefits paid to an injured employee that would have been payable by a No-Fault (PIP) carrier.

12
Husson v. Meekergreen
coloctapp · 1991 · cited in 1 Colorado opinions naming this issue, 2009–2009
1 sentence

2009No. 07CA2063, Dec. 11, 2008) (refusing to read a primacy requirement into coverage mandated by statute at issue where different statute expressly included such a requirement, thus showing that the General Assembly knew how to identify primary insurance coverage when it intended to do so); Husson v. Meeker, 812 P.2d 731, 733 (Colo.App.1991) (where different section of Workers' Compensation Act expressly provided for prejudgment interest, division would not infer that legislature inadvertently failed to provide for such interest in the statute at issue, because legislature knew how to deal with

11
Travelers Indemnity Company v. Barnesgreen
colo · 1976 · cited in 1 Colorado opinions naming this issue, 2009–2009
2 sentences

2009See Travelers Indemmity Co. v. Barnes, 191 Colo. 278, 283 , 552 P.2d 300, 304 (1976) (primacy scheme in former section 10-4-707(4) limited to PIP coverages, and would not be extended by implication to liability coverage).

2009See Travelers Indemmity Co. v. Barnes, 191 Colo. 278, 283 , 552 P.2d 300, 304 (1976) (primacy scheme in former section 10-4-707(4) limited to PIP coverages, and would not be extended by implication to liability coverage).

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 (1)

CaseCitedYears
Comiskey v. Valley Forge Insurance Co. green
coloctapp · 1989
1 sentence

1994Comis-key v. Valley Forge Insurance Co., 781 P.2d 188 (Colo.App.1989); § 10-4-707(5), C.R.S. (1993 Cum.Supp.).

11994–1994

Where else courts name it

FL 6 (1992–1995) CO 6 (1994–2009) TX 2 (2023–2025) UT 2 (2013–2013)

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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