Colo. Rev. Stat. » Title 15
Colorado Revised Statutes

Colo. Rev. Stat. § 15-12-107 (2026)

Scope of proceedings - proceedings independent - exception

✓ current as of July 2026
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(1) Unless supervised administration as described in part 5 of this article is involved:

(a) Each proceeding before the court or registrar is independent of any other proceeding involving the same estate;

(b) Petitions for formal orders of the court may combine various requests for relief in a single proceeding if the orders sought may be finally granted without delay. Except as required for proceedings which are particularly described by other sections of this article, no petition is defective because it fails to embrace all matters which might then be the subject of a final order;

(c) Proceedings for probate of wills or adjudications of no will may be combined with proceedings for appointment of personal representatives; and

(d) A proceeding for appointment of a personal representative is concluded by an order making or declining the appointment.

Source: L. 73: R&RE, p. 1566, § 1. C.R.S. 1963: § 153-3-107.

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 2000–2026 · leading case: Scott v. Scott, 136 P.3d 892 (Colo. 2006).
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Scott v. Scott, 136 P.3d 892 (Colo. 2006). · cites it 8× “Section 15-12-107, C.R.S. (2005), entitled “Scope of proceedings,” states that unless supervised administration is involved “[ejach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
In Re Est. of Scott, 151 P.3d 642 (Colo. Ct. App. 2006). · cites it 10× “Section 15-12-107, C.R.S. (2005), entitled "Scope of proceedings," states that unless supervised administration is involved "[e]ach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
Scott v. Scott, 119 P.3d 511 (Colo. Ct. App. 2004). · cites it 2× “See § 15-12-107, C.R.S.2004 {unless supervised administration is involved, each proceeding before the court is independent of any other proceeding involving the same estate; proceedings for probate of wills may be combined with proceedings for appointment of personal…”
In Re Est. of Bell, 4 P.3d 504 (Colo. Ct. App. 2000). · cites it 4× “In doing so, we reject the estate's argument, in reliance upon § 15-12-107, C.R.S. 1999, that the Larges were not barred from raising their claims to the property, as compensation *507 for services and as devisees under the will, in the same proceeding.”
Large v. Bell, 4 P.3d 504 (Colo. Ct. App. 2000). · cites it 4× “In doing so, we reject the estate's argument, in reliance upon § 15-12-107, C.R.S. 1999, that the Larges were not barred from raising their claims to the property, as com *507 pensation for services and as devisees under the will, in the same proceeding.”
Est. of Wallace (Colo. Ct. App. 2026). · cites it 2× “” Scott, 6 136 P.3d at 896. An unsupervised administration of an estate may involve multiple proceedings, and each proceeding is independent of every other proceeding.”
Colo. Rev. Stat. § 15-12-107(1)(a): 2 cases
In Re Est. of Scott, 151 P.3d 642 (Colo. Ct. App. 2006). “Section 15-12-107, C.R.S. (2005), entitled "Scope of proceedings," states that unless supervised administration is involved "[e]ach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
Est. of Wallace (Colo. Ct. App. 2026). “” Scott, 6 136 P.3d at 896. An unsupervised administration of an estate may involve multiple proceedings, and each proceeding is independent of every other proceeding.”
Colo. Rev. Stat. § 15-12-107(1)(b): 1 case
In Re Est. of Scott, 151 P.3d 642 (Colo. Ct. App. 2006). “Section 15-12-107, C.R.S. (2005), entitled "Scope of proceedings," states that unless supervised administration is involved "[e]ach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
Colo. Rev. Stat. § 15-12-107(l)(a): 2 cases
Scott v. Scott, 136 P.3d 892 (Colo. 2006). “Section 15-12-107, C.R.S. (2005), entitled “Scope of proceedings,” states that unless supervised administration is involved “[ejach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
In Re Est. of Scott, 151 P.3d 642 (Colo. Ct. App. 2006). “Section 15-12-107, C.R.S. (2005), entitled "Scope of proceedings," states that unless supervised administration is involved "[e]ach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
Colo. Rev. Stat. § 15-12-107(l)(b): 2 cases
Scott v. Scott, 136 P.3d 892 (Colo. 2006). “Section 15-12-107, C.R.S. (2005), entitled “Scope of proceedings,” states that unless supervised administration is involved “[ejach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
In Re Est. of Scott, 151 P.3d 642 (Colo. Ct. App. 2006). “Section 15-12-107, C.R.S. (2005), entitled "Scope of proceedings," states that unless supervised administration is involved "[e]ach proceeding before the court or registrar is independent of any other proceeding involving the same estate.”
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