Colorado Revised Statutes

Colo. Rev. Stat. § 14-10-118 (2026)

Enforcement of orders

✓ current as of July 2026
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(1) Repealed.

(2) The court has the power to require security to be given to insure enforcement of its orders, in addition to other methods of enforcing court orders prescribed by statute or by the Colorado rules of civil procedure on or after July 6, 1973.

Source: L. 71: R&RE, p. 528, § 1. C.R.S. 1963: § 46-1-18. L. 73: p. 554, § 9. L. 81: (1) amended, p. 909, § 3, effective June 8. L. 82: (1) amended, p. 280, § 3, effective April 7. L. 87:

(1) amended, p. 595, § 25, effective July 10. L. 92: (1) amended, p. 577, § 5, effective July 1. L. 93: (1) amended, p. 1871, § 5, effective June 6. L. 94: (1) amended, p. 1252, § 6, effective July 1. L. 96: (1) repealed, p. 598, § 8, effective July 1.

Notes of Decisions
Cited in 35 cases (4 in the last 5 years), 1981–2026 · leading case: In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013).
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). · cites it 16× “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
IN RE the MARRIAGE OF Delinda EVANS, & Kenneth Evans, 504 P.3d 988 (Colo. Ct. App. 2021). · cites it 7× “Because the decision to order security under section 14-10-118 is discretionary with the court, we review its order for an abuse of that discretion.”
In Re the Marriage of Burford, 26 P.3d 550 (Colo. Ct. App. 2001). · cites it 15× “She contends that the court erred in failing to add the increase in value of his separate assets resulting from the reduction in debt, that the allocation of this increase to husband resulted in an unjust and inequitable property distribution, and that the court's refusal to…”
In Re the Marriage of Powell, 220 P.3d 952 (Colo. Ct. App. 2009). · cites it 7× “Section 14-10-118(1), in pertinent part, provides: In a proceeding for dissolution of marriage .”
In re the Marriage of de Koning, 2016 CO 2 (Colo. 2016). · cites it 2× “" § 14-10-118(1)(c). Critically, "property shall be valued as of the date of the decree or as of the date of the hearing on disposition of property if such hearing precedes the date of the decree.”
In re the Marriage of Cardona, 316 P.3d 626 (Colo. 2014). · cites it 4× “1 11 In Colorado, section 14-10-118, C.R.S. (2018), of the UDMA requires the court to make an equitable distribution of marital property after considering all relevant factors, including the contributions of each spouse, the value of property set apart to each spouse, the…”
In Re the Marriage of Schmedeman, 190 P.3d 788 (Colo. Ct. App. 2008). · cites it 6× “Section 14-10-118(1), C.R.8.2007, is clear and unambiguous.”
In Re Marriage of Amich & Adiutori, 192 P.3d 422 (Colo. Ct. App. 2007). · cites it 3× “Section 14-10-118(1), C.R.S.2007, provides that the court shall set apart to each spouse his or her separate property and shall divide the marital property, without regard to marital misconduct, in such proportions as the court deems just after considering all relevant factors.”
In Re the Marriage of Nevarez, 170 P.3d 808 (Colo. Ct. App. 2007). · cites it 3× “Section 14-10-118(5), C.R.S.2006 ("[PJroperty shall be valued as of the date of the decree or as of the date of the hearing on disposition of property if such hearing precedes the date of the decree.”
In Re the Marriage of Balanson, 25 P.3d 28 (Colo. 2001). · cites it 2× “§ 14-10-118(2). The Act thus creates a presumption that all property acquired during the marriage is marital property, unless the property in question falls within the listed exceptions.”
In Re the Marriage of Dale, 87 P.3d 219 (Colo. Ct. App. 2004). · cites it 4× “In re Marriage of Balanson, supra, also holds that the appreciation in a vested remainder interest in an irrevocable trust during the course of the marriage constitutes marital property under § 14-10-118(4), C.R.S.2003. We cannot distinguish wife's interest in her grandfather's…”
In Re the Marriage of Seewald, 22 P.3d 580 (Colo. Ct. App. 2001). · cites it 4× “Here, the trial court found that husband was the owner of the trust assets and that, to the extent an item of property held by the trust was acquired during the marriage and not in a manner set forth in § 14-10-118(2), such an item would be treated and divided as marital…”
Colo. Rev. Stat. § 14-10-118(1): 12 cases
In Re the Marriage of Powell, 220 P.3d 952 (Colo. Ct. App. 2009). “Section 14-10-118(1), in pertinent part, provides: In a proceeding for dissolution of marriage .”
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
In Re Marriage of Amich & Adiutori, 192 P.3d 422 (Colo. Ct. App. 2007). “Section 14-10-118(1), C.R.S.2007, provides that the court shall set apart to each spouse his or her separate property and shall divide the marital property, without regard to marital misconduct, in such proportions as the court deems just after considering all relevant factors.”
In Re the Marriage of Schmedeman, 190 P.3d 788 (Colo. Ct. App. 2008). “Section 14-10-118(1), C.R.8.2007, is clear and unambiguous.”
In re the Marriage of Cardona, 316 P.3d 626 (Colo. 2014). “1 11 In Colorado, section 14-10-118, C.R.S. (2018), of the UDMA requires the court to make an equitable distribution of marital property after considering all relevant factors, including the contributions of each spouse, the value of property set apart to each spouse, the…”
Colo. Rev. Stat. § 14-10-118(1)(a): 1 case
In Re the Marriage of Burford, 26 P.3d 550 (Colo. Ct. App. 2001). “She contends that the court erred in failing to add the increase in value of his separate assets resulting from the reduction in debt, that the allocation of this increase to husband resulted in an unjust and inequitable property distribution, and that the court's refusal to…”
Colo. Rev. Stat. § 14-10-118(1)(c): 3 cases
In Re the Marriage of Burford, 26 P.3d 550 (Colo. Ct. App. 2001). “She contends that the court erred in failing to add the increase in value of his separate assets resulting from the reduction in debt, that the allocation of this increase to husband resulted in an unjust and inequitable property distribution, and that the court's refusal to…”
In re the Marriage of de Koning, 2016 CO 2 (Colo. 2016). “" § 14-10-118(1)(c). Critically, "property shall be valued as of the date of the decree or as of the date of the hearing on disposition of property if such hearing precedes the date of the decree.”
In Re the Marriage of Foss, 30 P.3d 850 (Colo. Ct. App. 2001).
Colo. Rev. Stat. § 14-10-118(1)(d): 1 case
In Re the Marriage of Burford, 26 P.3d 550 (Colo. Ct. App. 2001). “She contends that the court erred in failing to add the increase in value of his separate assets resulting from the reduction in debt, that the allocation of this increase to husband resulted in an unjust and inequitable property distribution, and that the court's refusal to…”
Colo. Rev. Stat. § 14-10-118(2): 16 cases
IN RE the MARRIAGE OF Delinda EVANS, & Kenneth Evans, 504 P.3d 988 (Colo. Ct. App. 2021). “Because the decision to order security under section 14-10-118 is discretionary with the court, we review its order for an abuse of that discretion.”
In Re the Marriage of Schmedeman, 190 P.3d 788 (Colo. Ct. App. 2008). “Section 14-10-118(1), C.R.8.2007, is clear and unambiguous.”
In Re the Marriage of Balanson, 25 P.3d 28 (Colo. 2001). “§ 14-10-118(2). The Act thus creates a presumption that all property acquired during the marriage is marital property, unless the property in question falls within the listed exceptions.”
In Re the Marriage of Powell, 220 P.3d 952 (Colo. Ct. App. 2009). “Section 14-10-118(1), in pertinent part, provides: In a proceeding for dissolution of marriage .”
In Re the Marriage of Jaeger, 883 P.2d 577 (Colo. Ct. App. 1994).
Colo. Rev. Stat. § 14-10-118(2)(a): 2 cases
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
In Re the Marriage of Schmedeman, 190 P.3d 788 (Colo. Ct. App. 2008). “Section 14-10-118(1), C.R.8.2007, is clear and unambiguous.”
Colo. Rev. Stat. § 14-10-118(2)(d): 1 case
In re the Marriage of Paige, 282 P.3d 506 (Colo. Ct. App. 2012).
Colo. Rev. Stat. § 14-10-118(4): 6 cases
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
In Re the Marriage of Seewald, 22 P.3d 580 (Colo. Ct. App. 2001). “Here, the trial court found that husband was the owner of the trust assets and that, to the extent an item of property held by the trust was acquired during the marriage and not in a manner set forth in § 14-10-118(2), such an item would be treated and divided as marital…”
In Re the Marriage of Lewis, 66 P.3d 204 (Colo. Ct. App. 2003).
In Re the Marriage of Burford, 26 P.3d 550 (Colo. Ct. App. 2001). “She contends that the court erred in failing to add the increase in value of his separate assets resulting from the reduction in debt, that the allocation of this increase to husband resulted in an unjust and inequitable property distribution, and that the court's refusal to…”
In Re the Marriage of Dale, 87 P.3d 219 (Colo. Ct. App. 2004). “In re Marriage of Balanson, supra, also holds that the appreciation in a vested remainder interest in an irrevocable trust during the course of the marriage constitutes marital property under § 14-10-118(4), C.R.S.2003. We cannot distinguish wife's interest in her grandfather's…”
Colo. Rev. Stat. § 14-10-118(5): 3 cases
In Re the Marriage of Nevarez, 170 P.3d 808 (Colo. Ct. App. 2007). “Section 14-10-118(5), C.R.S.2006 ("[PJroperty shall be valued as of the date of the decree or as of the date of the hearing on disposition of property if such hearing precedes the date of the decree.”
In re the Marriage of de Koning, 2016 CO 2 (Colo. 2016). “" § 14-10-118(1)(c). Critically, "property shall be valued as of the date of the decree or as of the date of the hearing on disposition of property if such hearing precedes the date of the decree.”
In Re the Marriage of Balanson, 25 P.3d 28 (Colo. 2001). “§ 14-10-118(2). The Act thus creates a presumption that all property acquired during the marriage is marital property, unless the property in question falls within the listed exceptions.”
Colo. Rev. Stat. § 14-10-118(6): 1 case
Colo. Rev. Stat. § 14-10-118(7)(a): 1 case
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
Colo. Rev. Stat. § 14-10-118(7)(b): 1 case
In Re the Marriage of Dale, 87 P.3d 219 (Colo. Ct. App. 2004). “In re Marriage of Balanson, supra, also holds that the appreciation in a vested remainder interest in an irrevocable trust during the course of the marriage constitutes marital property under § 14-10-118(4), C.R.S.2003. We cannot distinguish wife's interest in her grandfather's…”
Colo. Rev. Stat. § 14-10-118(8): 3 cases
In re the Marriage of Krejci, 297 P.3d 1035 (Colo. Ct. App. 2013). “113 Any appreciation of a spouse's separate property during the marriage is marital property subject to equitable division under section 14-10-118(1), C.R.S.2012. See Balanson, 25 P.”
Marriage of Martinez v. Gutierrez-Martinez, 77 P.3d 827 (Colo. Ct. App. 2003).
People v. Sullivan, 53 P.3d 1181 (Colo. Ct. App. 2002).
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