Colo. Rev. Stat. » Title 13
Colorado Revised Statutes

Colo. Rev. Stat. § 13-22-214 (2026)

Immunity of arbitrator - competency to testify - attorney fees and costs

✓ current as of July 2026
Find cases: SyfertCases citing this section CO-LEGleg.colorado.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

(1) An arbitrator or an arbitration organization acting in the capacity of an arbitrator is immune from civil liability to the same extent as a judge of a court of this state acting in a judicial capacity.

(2) The immunity afforded by this section is in addition to, and not in lieu of, or in derogation of, immunity conferred under any other provision of law.

(3) The failure of an arbitrator to make a disclosure required by section 13-22-212 shall not cause any loss of immunity that is granted under this section.

(4) (a) In a judicial proceeding, administrative proceeding, or other similar proceeding, an arbitrator or representative of an arbitration organization shall not be competent to testify and may not be required to produce records as to any statement, conduct, decision, or ruling that occurred during the arbitration proceeding, to the same extent as a judge of a court of this state acting in a judicial capacity.

(b) This subsection (4) shall not apply: (I) To the extent necessary to determine the claim of an arbitrator, arbitration organization, or representative of the arbitration organization against a party to the arbitration proceeding; or (II) To a hearing on a motion to vacate an award under section 13-22-223 (1)(a) or (1)(b) if the movant makes a prima facie showing that a ground for vacating the award exists.

(5) If a person commences a civil action against an arbitrator, arbitration organization, or representative of an arbitration organization arising from the services of the arbitrator, organization, or representative, or if a person seeks to compel an arbitrator or a representative of an arbitration organization to testify or produce records in violation of subsection (4) of this section, and the court decides that the arbitrator, arbitration organization, or representative of an arbitration organization is immune from civil liability or that the arbitrator or representative of the organization is not competent to testify, the court shall award to the arbitrator, organization, or representative reasonable attorney fees and reasonable expenses of litigation.

Source: L. 2004: Entire part R&RE, p. 1724, § 1, effective August 4.

Notes of Decisions
Cited in 43 cases, 1980–2012 · leading case: Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998).
Sort: Relevance Newest Treatment
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). · cites it 56× “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Coors Brewing Co. v. Cabo, 114 P.3d 60 (Colo. Ct. App. 2004). · cites it 9× “Thus, we conclude, the inquiry under former § 13-22-214(1)(a)(III) concerns whether an arbitrator acted within the scope of his contractual authority, not whether' the arbitrator’s legal rulings were correct.”
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). · cites it 12× “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
State Farm Mut. Auto. Ins. Co. v. Cabs, Inc., 751 P.2d 61 (Colo. 1988). · cites it 14× “(1987), provides that “[u]pon application of a party, the court shall confirm an award, unless within the time limits imposed in this part 2 grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections…”
Carson v. PaineWebber, Inc., 62 P.3d 996 (Colo. Ct. App. 2002). · cites it 19× “Section 13-22-214, C.R.S.2001; see also Foust v.”
Huizar v. Allstate Ins. Co., 952 P.2d 342 (Colo. 1998). · cites it 6× “00, it may either be confirmed as provided by section 13-22-213, vacated on the specific grounds provided for in section 13-22-214, or modified for the specific reasons provided for in sections 13-22-214 to -215.”
Applehans v. Farmers Ins. Exch., 68 P.3d 594 (Colo. Ct. App. 2003). · cites it 5× “Plaintiff then filed a motion under §§ 13-22-214 and 13-22-215, C.R.9.2002, seeking to vacate, modify, or correct the final award.”
Osborn v. Packard, 117 P.3d 77 (Colo. Ct. App. 2004). · cites it 3× ““Upon application of a party, the court shall confirm an award, unless within the time limits imposed in this part 2 grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections 13-22-214 and 13-22-215.” Colo.…”
Byerly v. Kirkpatrick Pettis Smith Polian, Inc., 996 P.2d 771 (Colo. Ct. App. 2000). · cites it 6× “Section 13-22-214, C.R.S.1999; Red Carpet Armory Realty Co.”
Am. Numismatic Ass'n v. Cipoletti, 254 P.3d 1169 (Colo. Ct. App. 2011). · cites it 6× “We conclude that the arbitrator's May 27, 2009, "Order RE: Respondent's Motion to Dismiss" was an "award" that triggered the time limit for judicial review under former section 13-22-214. It completely disposed of all claims on the merits.”
Cabus v. Dairyland Ins. Co., 656 P.2d 54 (Colo. Ct. App. 1982). · cites it 5× “848 (1931); see also § 13-22-214(1)(b), C.R.S.1973 (1981 Cum. Supp.”
Judd Constr. Co. v. Evans Jt. Venture, 642 P.2d 922 (Colo. 1982). · cites it 3× “” Section 13-22-214, C.R.S. 1973 (1981 Supp.”
Show all 43 citing cases →
Colo. Rev. Stat. § 13-22-214(1): 4 cases
Byerly v. Kirkpatrick Pettis Smith Polian, Inc., 996 P.2d 771 (Colo. Ct. App. 2000). “Section 13-22-214, C.R.S.1999; Red Carpet Armory Realty Co.”
Red Carpet Armory Realty Co. v. Golden West Realty, 644 P.2d 93 (Colo. Ct. App. 1982).
Container Tech. Corp. v. J. Gadsden Pty., Ltd., 781 P.2d 119 (Colo. Ct. App. 1989).
Liberty Mut. Ins. Co. v. Horace Mann Ins. Co., 36 P.3d 197 (Colo. Ct. App. 2001).
Colo. Rev. Stat. § 13-22-214(1)(a): 2 cases
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Superior Const. Co., Inc. v. Bentley, 104 P.3d 331 (Colo. Ct. App. 2004).
Colo. Rev. Stat. § 13-22-214(1)(a)(I): 3 cases
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Superior Const. Co., Inc. v. Bentley, 104 P.3d 331 (Colo. Ct. App. 2004).
Nasca v. State Farm Mut. Auto. Ins. Co., 12 P.3d 346 (Colo. Ct. App. 2000).
Colo. Rev. Stat. § 13-22-214(1)(a)(II): 2 cases
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Nasca v. State Farm Mut. Auto. Ins. Co., 12 P.3d 346 (Colo. Ct. App. 2000).
Colo. Rev. Stat. § 13-22-214(1)(a)(II1): 1 case
Farmers Ins. Exch. v. Taylor, 45 P.3d 759 (Colo. Ct. App. 2001).
Colo. Rev. Stat. § 13-22-214(1)(a)(III): 5 cases
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Magenis v. Bruner, 187 P.3d 1222 (Colo. Ct. App. 2008).
Coors Brewing Co. v. Cabo, 114 P.3d 60 (Colo. Ct. App. 2004). “Thus, we conclude, the inquiry under former § 13-22-214(1)(a)(III) concerns whether an arbitrator acted within the scope of his contractual authority, not whether' the arbitrator’s legal rulings were correct.”
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Cohen v. Quiat, 749 P.2d 453 (Colo. Ct. App. 1987).
Colo. Rev. Stat. § 13-22-214(1)(a)(IIl): 1 case
Applehans v. Farmers Ins. Exch., 68 P.3d 594 (Colo. Ct. App. 2003). “Plaintiff then filed a motion under §§ 13-22-214 and 13-22-215, C.R.9.2002, seeking to vacate, modify, or correct the final award.”
Colo. Rev. Stat. § 13-22-214(1)(a)(IV): 2 cases
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Liberty Mut. Ins. Co. v. Horace Mann Ins. Co., 36 P.3d 197 (Colo. Ct. App. 2001).
Colo. Rev. Stat. § 13-22-214(1)(a)(V): 2 cases
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
R.P.T. of Aspen, Inc. v. Innovative Commc'ns, Inc., 917 P.2d 340 (Colo. Ct. App. 1996).
Colo. Rev. Stat. § 13-22-214(1)(b): 2 cases
Coors Brewing Co. v. Cabo, 114 P.3d 60 (Colo. Ct. App. 2004). “Thus, we conclude, the inquiry under former § 13-22-214(1)(a)(III) concerns whether an arbitrator acted within the scope of his contractual authority, not whether' the arbitrator’s legal rulings were correct.”
Cabus v. Dairyland Ins. Co., 656 P.2d 54 (Colo. Ct. App. 1982). “848 (1931); see also § 13-22-214(1)(b), C.R.S.1973 (1981 Cum. Supp.”
Colo. Rev. Stat. § 13-22-214(2): 7 cases
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
State Farm Mut. Auto. Ins. Co. v. Cabs, Inc., 751 P.2d 61 (Colo. 1988). “(1987), provides that “[u]pon application of a party, the court shall confirm an award, unless within the time limits imposed in this part 2 grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections…”
Am. Numismatic Ass'n v. Cipoletti, 254 P.3d 1169 (Colo. Ct. App. 2011). “We conclude that the arbitrator's May 27, 2009, "Order RE: Respondent's Motion to Dismiss" was an "award" that triggered the time limit for judicial review under former section 13-22-214. It completely disposed of all claims on the merits.”
Nasca v. State Farm Mut. Auto. Ins. Co., 12 P.3d 346 (Colo. Ct. App. 2000).
South Conejos Sch. Dist. RE-10 v. Martinez, 709 P.2d 594 (Colo. Ct. App. 1985).
Colo. Rev. Stat. § 13-22-214(3): 1 case
Int'l Bhd. of Elec. Workers, Local Union 1823 v. WGN of Colorado, Inc., 615 F. Supp. 64 (D. Colo. 1985).
Colo. Rev. Stat. § 13-22-214(4): 1 case
South Conejos Sch. Dist. RE-10 v. Martinez, 709 P.2d 594 (Colo. Ct. App. 1985).
Colo. Rev. Stat. § 13-22-214(a)(III): 1 case
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Colo. Rev. Stat. § 13-22-214(l)(a): 3 cases
Coors Brewing Co. v. Cabo, 114 P.3d 60 (Colo. Ct. App. 2004). “Thus, we conclude, the inquiry under former § 13-22-214(1)(a)(III) concerns whether an arbitrator acted within the scope of his contractual authority, not whether' the arbitrator’s legal rulings were correct.”
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Kutch v. State Farm Mut. Auto. Ins. Co., 944 P.2d 623 (Colo. Ct. App. 1997).
Colo. Rev. Stat. § 13-22-214(l)(a)(I): 1 case
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Colo. Rev. Stat. § 13-22-214(l)(a)(II): 4 cases
Carson v. PaineWebber, Inc., 62 P.3d 996 (Colo. Ct. App. 2002). “Section 13-22-214, C.R.S.2001; see also Foust v.”
McNaughton & Rodgers v. Besser, 932 P.2d 819 (Colo. Ct. App. 1996).
Giraldi by & Through Giraldi v. Morrell, 892 P.2d 422 (Colo. Ct. App. 1994).
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Colo. Rev. Stat. § 13-22-214(l)(a)(III): 12 cases
Coors Brewing Co. v. Cabo, 114 P.3d 60 (Colo. Ct. App. 2004). “Thus, we conclude, the inquiry under former § 13-22-214(1)(a)(III) concerns whether an arbitrator acted within the scope of his contractual authority, not whether' the arbitrator’s legal rulings were correct.”
Kutch v. State Farm Mut. Auto. Ins. Co., 960 P.2d 93 (Colo. 1998). “The trial court ruled that it would not consider State Farm's policy limit defense because State Farm had failed "to appeal the unfavorable ruling of the arbitrators by means of [a] section 13-22-214 application to vacate or modify within ninety days" of the award.”
Carson v. PaineWebber, Inc., 62 P.3d 996 (Colo. Ct. App. 2002). “Section 13-22-214, C.R.S.2001; see also Foust v.”
Cabus v. Dairyland Ins. Co., 656 P.2d 54 (Colo. Ct. App. 1982). “848 (1931); see also § 13-22-214(1)(b), C.R.S.1973 (1981 Cum. Supp.”
State Farm Mut. Auto. Ins. Co. v. Cabs, Inc., 751 P.2d 61 (Colo. 1988). “(1987), provides that “[u]pon application of a party, the court shall confirm an award, unless within the time limits imposed in this part 2 grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections…”
Colo. Rev. Stat. § 13-22-214(l)(a)(IV): 2 cases
Carson v. PaineWebber, Inc., 62 P.3d 996 (Colo. Ct. App. 2002). “Section 13-22-214, C.R.S.2001; see also Foust v.”
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Colo. Rev. Stat. § 13-22-214(l)(a)(V): 2 cases
State Farm Mut. Auto. Ins. Co. v. Cabs, Inc., 751 P.2d 61 (Colo. 1988). “(1987), provides that “[u]pon application of a party, the court shall confirm an award, unless within the time limits imposed in this part 2 grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections…”
State Farm Mut. Auto. Ins. Co. v. Broadnax, 827 P.2d 531 (Colo. 1992). “§ 13-22-214, 6A C.R.S. (1987). Parties may also apply to courts to modify or correct arbitration awards where there was an evident mistake or where the award was premised on a matter not submitted to the arbitrators.”
Colo. Rev. Stat. § 13-22-214(l)(b): 1 case
R.P.T. of Aspen, Inc. v. Innovative Commc'ns, Inc., 917 P.2d 340 (Colo. Ct. App. 1996).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.