Colo. Rev. Stat. » Title 2
Colorado Revised Statutes

Colo. Rev. Stat. § 2-4-206 (2024)

Irreconcilable statutes passed at the same or different sessions

✓ C.R.S. 2024: the 2025 and 2026 sessions are not included
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If statutes enacted at the same or different sessions of the general assembly are irreconcilable, the statute prevails which is latest in its effective date. If the irreconcilable statutes have the same effective date, the statute prevails which is latest in its date of passage.

Source: L. 73: R&RE, p. 1424, § 1. C.R.S. 1963: § 135-1-206.

Cross references: For harmonization of amendments to the same statute, see § 2-4-301.

Notes of Decisions
Cited in 49 cases (2 in the last 5 years), 1978–2025 · leading case: In Re Marriage of Rozzi, 190 P.3d 815 (Colo. Ct. App. 2008).
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In Re Marriage of Rozzi, 190 P.3d 815 (Colo. Ct. App. 2008). · cites it 6× “See § 2-4-206, C.R.S.2007; City of Florence v.”
Jenkins v. Panama Canal Ry. Co., 208 P.3d 238 (Colo. 2009). · cites it 9× “§ 2-4-206, C.R.S. (2008). As explained above, when the more recent statute is a general provision, it cannot prevail over an earlier-enacted specific provision unless the General Assembly manifestly intends it to do so.”
09 In re the Marriage of Zander, 2019 COA 149, 486 P.3d 352. · cites it 2× “§ 2-4-206, C.R.S. 2019. ¶ 14 The UDMA, enacted in 1971, creates a statutory presumption that property acquired during the marriage is marital property.”
Bd. of Cnty. Commissioners v. Hygiene Fire Prot. Dist., 221 P.3d 1063 (Colo. 2009). · cites it 10× “2d 1256, 1257 (1972); see also § 2-4-206, C.R.S. (2009). Specific provisions control over general provisions.”
Samuel Perez v. By the Rockies, LLC, & Duane Layton, 2023 COA 109, 543 P.3d 1054. · cites it 2× “2023 (special prevails over general); § 2-4-206, C.R.S. 2023 (latest effective date prevails); see also Jenkins v.”
City of Florence v. Pepper, 145 P.3d 654 (Colo. 2006). · cites it 5× “Section 2-4-206, C.R.S. (2006) states: If statutes enacted at the same or different sessions of the general assembly are irreconcilable, the statute prevails which is latest in its effective date.”
Frazier v. People, 90 P.3d 807 (Colo. 2004). · cites it 3× “§ 2-4-206, 1 C.R.S. (2003) (“If statutes enacted at the same or different sessions of the general assembly are irreconcilable, the statute prevails which is latest in its effective date.”
Nowak v. Suthers, 2014 CO 14, 320 P.3d 340. · cites it 2× “5-101 under section 2-4-206 merely because it has the later effective date.”
People v. Summers, 208 P.3d 251 (Colo. 2009). · cites it 4× “See § 2-4-206, C.R.S. (2008). Although the legislature has not expressly provided for a conflict between an act's substantive provisions and effective date clause, its preference for recency is clear, and as a simple matter of logic, a particular provision of a legislative…”
West v. Roberts, 143 P.3d 1037 (Colo. 2006). · cites it 4× “§ 2-4-206, C.R.S. (2006); Slater v. McKinna, 997 P.”
People v. Owens, 670 P.2d 1233 (Colo. 1983). · cites it 5× “The defendant maintains that this issue is controlled by section 2-4-206, C.R.S.1973 (1980 RepLVol.”
Martin v. People, 27 P.3d 846 (Colo. 2001). “Furthermore, where conflicting statutes are not related as general and specific statutes, the statute with the effective date that is latest in time prevails, see § 2-4-206, and even if the newer statute can be characterized as the more general, it still prevails if the manifest…”
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