Colorado Revised Statutes

Colo. Rev. Stat. § 13-20-601 (2026)

Legislative declaration

✓ current as of July 2026

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The general assembly hereby declares that, in enacting this part 6, the general assembly has determined that the certificate of review requirement should be utilized in civil actions for negligence brought against those professionals who are licensed by this state to practice a particular profession and regarding whom expert testimony would be necessary to establish a prima facie case.

Source: L. 87: Entire part added, p. 549, § 1, effective July 1.

13-20-602. Actions against licensed professionals and acupuncturists - certificate of review required. (1) (a) In every action for damages or indemnity based upon the alleged professional negligence of an acupuncturist regulated pursuant to article 200 of title 12 or a licensed professional, the plaintiff's or complainant's attorney shall file with the court a certificate of review for each acupuncturist or licensed professional named as a party, as specified in subsection (3) of this section, within sixty days after the service of the complaint, counterclaim, or cross claim against such person unless the court determines that a longer period is necessary for good cause shown.

(b) A certificate of review shall be filed with respect to every action described in paragraph (a) of this subsection (1) against a company or firm that employed a person specified in such paragraph (a) at the time of the alleged negligence, even if such person is not named as a party in such action.

(2) In the event of failure to file a certificate of review in accordance with this section and if the acupuncturist or licensed professional defending the claim believes that an expert is necessary to prove the claim of professional negligence, the defense may move the court for an order requiring filing of such a certificate. The court shall give priority to deciding such a motion, and in no event shall the court allow the case to be set for trial without a decision on such motion.

(3) (a) A certificate of review shall be executed by the attorney for the plaintiff or complainant declaring:

(I) That the attorney has consulted a person who has expertise in the area of the alleged negligent conduct; and

(II) That the professional who has been consulted pursuant to subparagraph (I) of this paragraph (a) has reviewed the known facts, including such records, documents, and other materials which the professional has found to be relevant to the allegations of negligent conduct and, based on the review of such facts, has concluded that the filing of the claim, counterclaim, or cross claim does not lack substantial justification within the meaning of section 13-17-102 (4).

(b) The court, in its discretion, may require the identity of the acupuncturist or licensed professional who was consulted pursuant to subparagraph (I) of paragraph (a) of this subsection (3) to be disclosed to the court and may verify the content of such certificate of review. The identity of the professional need not be identified to the opposing party or parties in the civil action.

(c) In an action alleging professional negligence of a physician, the certificate of review shall declare that the person consulted meets the requirements of section 13-64-401; or in any action against any other professional, that the person consulted can demonstrate by competent evidence that, as a result of training, education, knowledge, and experience, the consultant is competent to express an opinion as to the negligent conduct alleged.

(4) The failure to file a certificate of review in accordance with this section shall result in the dismissal of the complaint, counterclaim, or cross claim.

(5) These provisions shall not affect the rights and obligations under section 13-17-102.

Source: L. 87: Entire part added, p. 549, § 1, effective July 1. L. 89: (1), (3)(a)(II), and

(4) amended and (3)(c) added, p. 750, § 1, effective April 12. L. 95: (1), (2), and (3)(b) amended, p. 485, § 6, effective January 1, 1996. L. 98: (1) amended, p. 487, § 1, effective February 1, 1999. L. 2019: (1)(a) amended, (HB 19-1172), ch. 136, p. 1663, § 67, effective October 1.

PART 7 ACTIONS BASED ON ENVIRONMENTAL LIABILITY Law reviews: For comment, "Stemming the Tide of Lender Liability: Judicial and Legislative Reactions", see 67 Den. U. L. Rev. 453 (1990).

Notes of Decisions

Cited in 12 cases (1 in the last 5 years), 1989–2025 · leading case: Yadon v. Southward, 64 P.3d 909 (Colo. Ct. App. 2002).

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Yadon v. Southward, 64 P.3d 909 (Colo. Ct. App. 2002). · cites it 10× “" Section 13-20-601, C.R.S.2002. This broad language refers to civil actions generally; it is not limited to civil actions in which a plaintiff is represented by an attorney.”

Martinez v. Badis, 842 P.2d 245 (Colo. 1992). · cites it 10× “The general assembly hereby declares that, in enacting this part 6, the general assembly has determined that the certificate of review requirement should be utilized in civil actions for negligence brought against those professionals who are licensed by this state to practice a…”

State v. Nieto, 993 P.2d 493 (Colo. 2000). · cites it 4× “Legislative Purpose As context for the language used in section 13-20-602, the General Assembly declared its purpose in section 13-20-601. In section 601, the General Assembly stated that “the certificate of review requirement should be utilized in civil actions for negligence…”

Ehrlich Feedlot, Inc. v. Oldenburg, 140 P.3d 265 (Colo. Ct. App. 2006). · cites it 3× “Section 13-20-601, C.R.S.2005, sets forth the purpose of the statutory scheme governing actions against licensed professionals, as follows: The general assembly hereby declares that, in enacting this part 6, the general assembly has determined that the certificate of review…”

Nieto v. State, 952 P.2d 834 (Colo. Ct. App. 1998). · cites it 4× “Section 13-20-601, et seq., C.R.S.1997, is the version enacted in Colorado.”

Giron v. Koktavy, 124 P.3d 821 (Colo. Ct. App. 2005). · cites it 3× “Section 13-20-601, C.R.S.2004; see Shelton v.”

Badis v. Martinez, 819 P.2d 551 (Colo. Ct. App. 1991). · cites it 3× “101, §§ 13-20-601 and 13-20-602 at 549. See Salmon, 1988 Update on Colorado Tort Reform Legislation, 17 Colo.”

Boigegrain v. Gilbert, 784 P.2d 849 (Colo. Ct. App. 1989). “4th 170 (1982); § 13-20-601 et seq., C.R.S. (1987 Repl.Vol.”

Colorado Trust for Prot. & Benefits v. Souder, Miller & Assocs., Inc., 870 F. Supp. 2d 1173 (D. Colo. 2012). · cites it 2× “” C.R.S. § 13-20-601(l)(a). In response, the McCartys argue that defendant is not an “individual” for purposes of the statute, nor is Reid Allan, a geologist, required to be licensed under Colorado law.”

Shelton v. Penrose-St. Francis Healthcare Sys., 968 P.2d 132 (Colo. Ct. App. 1998). · cites it 3× “” Section 13-20-601, C.R.S.1997. See Martinez v.”

Singletary v. Conroy (D. Colo. 2025). · cites it 3× “See Colo. Rev. Stat. § 13-20-601 (4) (stating that failure to comply with the certificate statute “shall result in the dismissal of the complaint”).”

Carroll v. Schrader (D. Colo. 2020). · cites it 2× “§ 13-20-602 (requiring a certificate of review as condition precedent to bringing an action for damages against a licensed professional); see also Colo. Rev. Stat. Ann. § 13-20-601 (“[T]he certificate of review requirement should be utilized in civil actions for negligence…”

— Colo. Rev. Stat. § 13-20-601(3) — 1 case

Martinez v. Badis, 842 P.2d 245 (Colo. 1992). “The general assembly hereby declares that, in enacting this part 6, the general assembly has determined that the certificate of review requirement should be utilized in civil actions for negligence brought against those professionals who are licensed by this state to practice a…”

— Colo. Rev. Stat. § 13-20-601(l)(a) — 1 case

Colorado Trust for Prot. & Benefits v. Souder, Miller & Assocs., Inc., 870 F. Supp. 2d 1173 (D. Colo. 2012). “” C.R.S. § 13-20-601(l)(a). In response, the McCartys argue that defendant is not an “individual” for purposes of the statute, nor is Reid Allan, a geologist, required to be licensed under Colorado law.”

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