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Colorado Revised Statutes

Colo. Rev. Stat. § 15-11-806 (2026)

Reformation to correct mistakes

✓ current as of July 2026
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The court may reform the terms of a governing instrument other than a trust that is governed by section 15-5-415, even if unambiguous, to conform the terms to the transferor's intention if it is proved by clear and convincing evidence what the transferor's intent was and that the terms of the governing instrument were affected by a mistake of fact or law, whether in expression or inducement.

Source: L. 2009: Entire section added, (HB 09-1287), ch. 310, p. 1687, § 15, effective July 1, 2010. L. 2018: Entire section amended, (SB 18-180), ch. 169, p. 1193, § 10, effective January 1, 2019.

Cross references: For provisions relating to the time of taking effect or the provisions for transition of this code, see § 15-17-101.

Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 2012–2026 · leading case: In re Est. of Ramstetter v. Hostetler, 2016 COA 81 (Colo. Ct. App. 2016).
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In re Est. of Ramstetter v. Hostetler, 2016 COA 81 (Colo. Ct. App. 2016). · cites it 64× “¶ 3 We hold that the trial court properly excluded extrinsic evidence of Louise’s intent in executing the will, as the recently-enacted section 15-11-806, C.R.S. 2015, is not retroactive on these facts.”
Ramstetter v. Hostetler (In re Est. of Ramstetter), 411 P.3d 1043 (Colo. Ct. App. 2016). · cites it 64× “¶ 3 We hold that the trial court properly excluded extrinsic evidence of Louise's intent in executing the will, as the recently-enacted section 15-11-806, C.R.S.2015, is not retroactive on these facts.”
of Little, 2018 COA 169 (Colo. Ct. App. 2018). · cites it 33× “On that basis, he sought to reform Little’s will 5 pursuant to section 15-11-806, C.R.S. 2018, to reflect that intention.”
Christensen v. Wilson, 304 P.3d 614 (Colo. Ct. App. 2012). · cites it 13× “1 The trial court declined to apply section 15-11-806, C.R.S.2012, to reform Johnson's insurance policy because that section became effective after Johnson died and section 15-11-804(2) removed Christensen as beneficiary of Johnson's insurance policy.”
Baker v. Wood, Ris & Hames, Prof'l Corp., 2016 CO 5 (Colo. 2016). · cites it 3× “3d 614, 618 (implicitly recognizing that a disappointed beneficiary has standing to brmg a reformation claim under section 15-11-806 but concluding on the facts presented that the petitioner lacked standing because she had been removed as a beneficiary of the instrument at…”
Radin v. Jewish Nat'l Fund, 352 P.3d 863 (Cal. 2015). “) 15 Colorado ( Colo. Rev. Stat. § 15-11-806 ); Florida ( Fla.”
Est. of Curry (Colo. Ct. App. 2026). · cites it 13× “Instead, she merely argued, as relevant here, that summary judgment was inappropriate as to potential reformation of the will or joint trust agreement under section 15-11-806, C.R.S. 2025, because “[w]hether .”
Est. of Willis (Colo. Ct. App. 2025). · cites it 9× “Standard of Review and Applicable Law ¶ 33 Section 15-11-806, C.R.S. 2024, grants a court discretionary authority to reform the terms of a governing instrument to conform the terms to the transferor’s intent, if this intent “is proved by clear and convincing evidence” and the…”
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