Colo. Rev. Stat. § 13-80-101
Limitation of actions: the cases that interpreted this section
145 citing cases reviewed: 106 interpreted the section (annotated below), 39 cited it only in passing. Cases filed after 2026-06-12 may not have been reviewed yet.
Have a situation under Colo. Rev. Stat. § 13-80-101?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Later changes in law
Changes after the earliest notes below. A note stating a rule one of these changed is marked "Law changed since".
- 1994-07-01 The legislature added subsection (1)(n), giving motor vehicle bodily injury and property damage tort actions a three-year period. Source
- 2003-07-01 The Colorado Auto Accident Reparations Act was repealed, and subsection (1)(j) was changed from actions under that Act's former part 7 to actions under part 6 of title 10, article 4; the older CAARA notes concern claims governed by the former law. Source
- 2011-08-10 and 2013-08-07: The legislature repealed subsections (1)(o) and (1)(p); the remaining three-year categories continue in force. Source
Limitations period for actions accruing outside Colorado
Section 13-80-101(1)(k) extends the limitations period to three years for an action accruing outside Colorado when the limitation period where the action accrued is longer than Colorado's.
Catto v. Kelchner Enterprises · filed 1997-07-03(1)(k)
However, when an action accrues outside of the state, the limitations period is extended to three-years “if the limitation of actions of the place where the cause of action accrued is greater than that of this state.” Colo. Rev. Stat. § 13-80-101(1)(k).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) provides a three-year limitations period for contract actions, but it does not govern a Postal Service employee’s claim against a union that is substantively a duty-of-fair-representation claim.
Poletto v. Battaglino · filed 2024-04-24(1)(a)
Even liberally construing Mr. Poletto’s opening brief, we find only two arguments that are both adequately briefed and relevant to the basis of the district court’s dismissal ruling: (1) defendants failed to file an answer and (2) Colorado’s three-year statute of limitations for contract actions applies to the third claim. ... Regarding the second argument, we have carefully reviewed the record, the parties’ briefs, the magistrate judge’s recommendation, and the district court’s dismissal order in light of the controlling law. Having done so, we discern no reversible error in the district court’s analysis regarding the third claim and affirm for substantially the same reasons the district court stated in its thorough and well-reasoned order granting the motion to dismiss.Read the full opinion on CourtListener →
Three-year limitation for fraud, misrepresentation, concealment, or deceit
Section 13-80-101(1)(c) supplies a three-year limitations period for a Rule 10b-5 claim, subject to federal discovery tolling.
Dubin v. Miller · filed 1990-07-16(1)(c)
All parties concede that Colo.Rev. Stat. § 13-80-101(l)(c) (1987 Repl.Vol.) (formerly Colo. Rev. Stat. § 13-80-109 [1973]) supplies the three-year limitations period applicable to plaintiff’s claim. ... Therefore, because his complaint was filed on October 1, 1985, it is not barred.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) requires actions for fraud, misrepresentation, concealment, or deceit to be brought within three years after the cause of action accrues.
Rogers v. Nacchio · filed 2007-07-12(1)(c)
In Colorado, “[a]ll actions for fraud, misrepresentation, concealment, or deceit” must be brought “within three years after the cause of action accrues.” Colo. Rev. Stat. § 13-80-101(1)(c).Read the full opinion on CourtListener →
Section 13-80-101(c) provides a two-year limitations period for actions alleging fraud, misrepresentation, concealment, or deceit.
Stuhmer v. Girdner · filed 2021-11-18(c)
Plaintiff’s claims are subject to two-year and three-year statutes of limitations. See Colo. Rev. Stat. § 13-80-101(c) (actions for fraud, misrepresentation, concealment, or deceit), (h) (actions of replevin or for taking, detaining, or converting goods or chattels); ... At best, Defendants’ evidence indicates Plaintiff learned of one small aspect of their alleged fraudulent scheme when he received the 2015 K-1. But disputed facts remain over whether that fact alone was sufficient the blow the lid on the entire or ultimate scheme such that Plaintiff can be held to have had the requisite knowledge at that time to trigger the statute of limitations.Read the full opinion on CourtListener →
Section 13-80-101(l)(c) imposes a three-year limitations period for fraud actions, measured from accrual, and supplies the analogous limitations period for CEA antifraud claims.
Ebrahimi v. E.F. Hutton & Co. · filed 1988-08-02(l)(c)
By analogy to the federal securities cases, we will apply the general statute of limitations pertaining to fraud of three years, Colo.Rev.Stat. § 13-80-101(l)(c) (1987), to cases brought under the CEA.Read the full opinion on CourtListener →
Section 13-80-101(c) provides a three-year period for actions involving fraud, misrepresentation, concealment, or deceit, which would apply to the asserted fraudulent-transfer claim.
Kearns Motor Co. v. Cimino (In Re Dreiling) · filed 1999-04-07(c)
This would invoke a different statute of limitation, i.e., C.R.S. § 13-80-101(c) which provides a three-year period for the commencement of all actions for “fraud, misrepresentation, concealment or deceit.”Read the full opinion on CourtListener →
Section 13-80-101(c) provides a three-year limitations period for claims based on fraud or misrepresentation, including negligent misrepresentation and civil conspiracy alleging misrepresentation.
In Re Qwest Communications International, Inc. Securities Litigation · filed 2005-09-12(c)
The plaintiffs claims for common law fraud, for negligent misrepresentation, and for fraudulent concealment are, of course, claims based on allegations of fraud or misrepresentation. ... Thus, the three year statute of limitations of § 13-80-101(c) controls.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) allows three years to file a personal injury claim arising from a motor vehicle accident.
Oversole v. Manci · filed 2009-08-06(1)(n)(I)
Although in its order the trial court expressed concern that significant time had elapsed from the date of the accident to the filing of the complaint, the complaint was filed within the applicable three-year statute of limitations.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) sets a three-year limitations period for fraudulent misrepresentation claims.
EBH v. O'Hanlon · filed 2025-04-17(1)(c)
A claim for fraudulent misrepresentation — the sole claim EBH brought against O’Hanlon in the 2011 case — is subject to a three-year statute of limitations.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) generally requires actions for fraud, misrepresentation, concealment, or deceit to be commenced within three years after the cause of action accrues.
Topa v. Frechin · filed 2026-06-11(1)(c)
Under section 13-80-101(1)(c), C.R.S. 2025, “actions for fraud, misrepresentation, concealment, or deceit” generally must “be commenced within three years after the cause of action accrues.”Read the full opinion on CourtListener →
Three-year limit for actions under CAARA
Law changed since Colorado repealed the Auto Accident Reparations Act effective July 1, 2003, and changed § 13-80-101(1)(j) to refer to part 6 rather than that Act’s former part 7; this note describes a claim governed by the former law.
Section 13-80-101(1)(j) gives CAARA-based civil actions a three-year limitations period, regardless of the theory of suit, including claims arising from alleged CAARA violations.
Folks v. State Farm Mutual Insurance · filed 2008-10-20(1)(j)
Folks’ reformation claim is based on an alleged violation of CAARA. Although reformation is an equitable remedy, Folks’ claim, like Nelson’s, “clearly ‘arose from’ rights exclusively provided under CAARA and from the alleged violation of CAARA.” Id. at 1121. Therefore, the CAARA three-year statute of limitations applies to Folks’ reformation claim. Colo. Rev. Stat. § 13-80-101(1)(j). Folks’ remaining claims are also governed by this three-year statute of limitations.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives an insured three years to bring a motor vehicle personal injury action against a third-party tortfeasor when the action arises under the Colorado Auto Accident Reparations Act.
Jones v. Cox · filed 1992-04-06(1)(j)
In summary, we hold that because Cox’s claim is so intertwined with section 10-4-714 of the Act her claim falls “under” the Act for purposes of section 13—80—101(1)(j). We agree with the court of appeals that section 13-80-101, which is more specifically applicable than section 13-80-102, is the appropriate statute of limitations to apply.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Claims arising under the No-Fault Act have a three-year limitations period that controls over the borrowing limitations statute when both apply.
Grulke v. Erickson · filed 1996-02-22(1)(j)
Therefore, as discussed, because we cannot determine at this juncture that plaintiffs’ claims do not arise under the No-Fault Act, the remaining issue is whether the three-year no-fault limitations statute controls over the borrowing limitations statute. We conclude that it does.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives an insurer three years to bring a claim against an uninsured motorist when the insurer paid No-Fault Act benefits and the claim is intertwined with that Act.
Amco Insurance Co. v. Rockwell · filed 1997-04-10(1)(j)
Under these circumstances, we conclude that plaintiffs claim was intertwined with the No-Fault Act and was brought “under” it. Therefore, the three-year statute of limitations in § 13 — 80—101(1)(j) applies and the trial court’s ruling to the contrary was error.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) generally gives contract actions a three-year limitations period, but a claim for a liquidated debt falls under the separate six-year period.
Portercare Adventist Health System v. Lego · filed 2012-09-24(1)(a)
In general, contract actions are subject to a three-year statute of limitations. § 13-80-101(1)(a). If a contract is for a "liquidated debt" or for an "unliquidated, determinable amount," however, it falls under the six-year statute of limitations provided by section 13-80-108.5(1)(a).Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives a claimant three years to bring a claim arising under Colorado’s no-fault insurance law.
Murry v. GuideOne Specialty Mutual Insurance Co. · filed 2008-09-04(1)(j)
Regardless of the accrual date chosen, though the earliest would undoubtedly apply, the three-year statute of limitations expired well prior to the filing of her complaint in this proceeding in 2005.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives actions under the Colorado Auto Accident Reparations Act three years to be filed; a negligent propane-filling claim against someone who did not own, use, or operate the vehicle falls outside that period.
Grogan v. Taylor · filed 1994-08-08(1)(j)
However, the General Assembly has created an exception for “[a]ll actions under the Colorado Auto Accident Reparations Act”; such actions must be commenced within three years after the cause of action accrues. ... It did not fall “under” the No-Fault Act because defendant was not an owner, user, or operator of plaintiffs vehicle. Thus, the trial court properly concluded that plaintiffs’ action was subject to the two-year statute of limitations governing torts.Read the full opinion on CourtListener →
Statute of limitations—contract and fraud claims
Section 13-80-101(1) provides a three-year limitations period for contract actions other than claims to recover a liquidated debt or determinable amount of money.
Art Akiane LLC v. Art & SoulWorks LLC · filed 2026-03-31(1)
Second, as to breach of contract, the Colorado state law governing this subject8 sets two different statutes of limitations depending on the type of claim: six years for “[a]ll actions to recover a liquidated debt or an unliquidated, determinable amount of money due to the person bringing the action,” Colo. Rev. Stat. § 13-80-103.5(1)(a), and three years for other contract actions, Colo. Rev. Stat. § 13-80-101(1).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) establishes a three-year statute of limitations for contract actions.
Copper Creek Inc v. State Farm Fire and Casualty Company · filed 2022-12-06(1)(a)
Generally speaking, Colorado law provides a three-year statute of limitations for all contract actions. Colo. Rev. Stat. § 13-80-101(1)(a).Read the full opinion on CourtListener →
Section 13-80-101(1)(c) imposes a three-year limitations period on fraud claims.
McClaflin v. Sanofi-Aventis U.S. LLC · filed 2024-04-09(1)(c)
The parties agree that Colorado law governs this dispute. They also agree on the applicable limitation periods. ECF No. 55 at 11; ECF No. 58 at 5–6. Plaintiff’s negligence and strict liability claims are subject to Colorado’s two-year statute of limitations for product liability claims, Colo. Rev. Stat. § 13-80-106(1), and her fraud claims are subject to a three-year statute of limitations. Colo. Rev. Stat. § 13-80-101(1)(c). ... Like Plaintiff’s negligence and strict liability claims, the Court finds that Plaintiff’s fraud-based claims began to accrue no later than 2009. By then, she was aware of the injury and the cause. Even if Defendants did fraudulently conceal or misrepresent the side effects of Taxotere as Plaintiff alleges, the law required Plaintiff to exercise reasonable diligence to discover the fraud. Colo. Rev. Stat. § 13-80-108(3). ... Because Plaintiff did not file her lawsuit until December 11, 2017—long after the three-year statute of limitations expired on her fraud claims—her claims are time-barred.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) is the general three-year limitations provision for contract actions, but its exception leaves actions covered by section 13-80-103.5 subject to that section's six-year period.
Carson v. Ocwen Loan Servicing LLC · filed 2019-01-08(1)(a)
Section 13-80-101(1)(a), upon which Defendants rely, is the more general statute of the two at issue. ... Accordingly, the six-year statute applies.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) provides a three-year limitations period for fraud claims; the court held the claims timely because the limitations period had not begun before the filing cutoff.
WTI Partners v. Ahn · filed 2020-06-16(1)(c)
A three-year statute of limitations applies to claims sounding in fraud. Colo. Rev. Stat. § 13-80-101(1)(c).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) and (f) requires contract and breach-of-fiduciary-duty actions to be commenced within three years after the cause of action accrues.
Grant v. Pharmacia & Upjohn Co. · filed 2002-12-23(1)(a), (f)
Second, even if we were somehow to conclude that the ‘812 Patent was in force until 2003, the district court was correct to conclude that Colorado’s statute of limitations bars the Plaintiffs’ action. Colorado law provides that contract actions and actions for breach of fiduciary duty “shall be commenced within three years after the cause of action accrues.” Colo. Rev. Stat. § 13-80-101(1)(a), (f) (2002). ... Since this suit was not filed until approximately a decade after this notice, Plaintiffs allowed the three-year Colorado statute of limitations to expire.Read the full opinion on CourtListener →
Subsection (1)(s) provides a three-year limitations period for breach-of-contract claims.
Bank of America, N.A. v. Dakota Homestead Title Insurance · filed 2013-12-26(1)(s)
In Colorado, there is a three-year statute of limitations for breach of contract claims. See Colo. Rev. Stat. § 13-80-101(1)(s). A cause of action accrues “on the date the breach is discovered or should have been discovered by the exercise of reasonable diligence.” Id. § 13-80-108(6).Read the full opinion on CourtListener →
Section 13-80-101(1) requires contract actions to be commenced within three years after the cause of action accrues.
Happy Beavers LLC v. Angry Beavers, LLC · filed 2021-09-29(1)
Pursuant to Colorado Revised Statute § 13-80-101, “[a]ll contract actions” must “be commenced within three years after the cause of action accrues.” Colo. Rev. Stat. § 13-80-101(1).Read the full opinion on CourtListener →
Section 13-80-101(1)(c) bars a fraud claim filed more than three years after the alleged fraud and its discovery.
Martinez v. Allstate Insurance Company · filed 2021-09-30(1)(c)
The claim is alternatively barred by Colorado’s three-year statute of limitations, Colo. Rev. Stat. § 13-80-101(1)(c), because the alleged fraud took place in 2011, the accident and denial of benefits occurred in 2014, and Ms. Martinez did not file suit until October 2019.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) requires contract actions, regardless of the theory pleaded, to be commenced within three years after the cause of action accrues unless section 13-80-103.5 applies.
Voodoo Leatherworks LLC v. Waste Connections US, Inc · filed 2022-08-01(1)(a)
Under Colorado Law, “[a]ll contract actions . . . , except as otherwise provided in section 13-80-103.5” “regardless of the theory upon which suit is brought, . . . shall be commenced within three years after the cause of action accrues.” Colo. Rev. Stat. § 13-80-101(1)(a). ... Therefore, the three-year statute of limitations under section 13-80-101(1)(a) applies to Plaintiff’s breach of contract claim.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) supplies a three-year limitations period for an unjust-enrichment claim treated as a contract or quasi-contract claim.
Harper v. Biolife Energy Systems, LLC · filed 2022-09-08(1)(a)
First, a three-year statute of limitations period applies to Harper’s unjust enrichment claim. Colo. Rev. Stat. § 13-80-101(1)(a); Sterenbuch v. Goss, 266 P.3d 428, 437 (Colo. App. 2011) (“because unjust enrichment is a form of relief in quasi-contract or contract implied in law, . . . the time within which to assert such a claim ordinarily is assessed under the three-year statute of limitations for contract actions”).Read the full opinion on CourtListener →
Section 13-80-101(1)(f) requires an action for breach of fiduciary duty to be commenced within three years after the cause of action accrues.
In re: Stone Pine Investment Banking · filed 2023-12-19(1)(f)
Colorado law requires “[a]ll actions for . . . breach of fiduciary duty” shall be “commenced within three years after the cause of action accrues, and not thereafter.” Colo. Rev. Stat. § 13-80-101(1)(f). ... But the Trustee concedes no Colorado court has applied this theory. See Trustee Reply Br. at 23. Under these circumstances, we cannot conclude the bankruptcy court abused its discretion by declining to apply an equitable doctrine that no binding authority has adopted.Read the full opinion on CourtListener →
Section 13-80-101(1)(f) imposes a three-year limitations period on unjust-enrichment claims founded on breach of fiduciary duty, regardless of the theory or remedy.
Grynberg v. Total S.A. · filed 2008-08-26(1)(f)
Because Grynberg’s unjust-enrichment claims are founded on allegations of breach of fiduciary duty, the claims are encompassed by the statute.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) imposes a three-year limitations period on an unjust-enrichment claim when Colorado law governs.
Barnett v. Surefire Med. Inc. · filed 2018-09-23(1)(a)
Accordingly, to the extent that Colorado law governs plaintiff's unjust enrichment claim, the three-year statute of limitations period in ... Colo. Rev. Stat. § 13-80-101 ... (1)(a) applies.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) provides a three-year statute of limitations for claims for breach of contract, unjust enrichment, and promissory estoppel.
Wendelberger v. Linked.Exchange, LLC. · filed 2024-09-30(1)(a)
As for Plaintiff’s claims for breach of contract, unjust enrichment, and promissory estoppel, the statute of limitations is three years. Colo. Rev. Stat. § 13-80-101(1)(a). Plaintiff’s claims arose from her time working at Linked.Exchange from December 19, 2019, to January 31, 2022. If Plaintiff were to file anew in the Western District of North Carolina, it appears (as she argues) that at least some of her claims would be partially-time barred, at a minimum.Read the full opinion on CourtListener →
Section 13-80-101 bars a fraud suit three years after the fraud could have been discovered with due diligence.
In Re the Receivership Estate of Indian Motorcycle Manufacturing, Inc. · filed 2003-08-07
Under both the Massachusetts and Colorado statute of limitation, a suit based on fraud is time barred three years after the fraud could have been discovered with due diligence. ... Mandelman’s statement at the creditors’ meeting was enough to put the Receiver on notice that he should investigate the status of the judgment. ... For the above reasons, the Receiver’s claim is barred by the statute of limitation.Read the full opinion on CourtListener →
Section 13-80-101(l)(a) provides a three-year limitations period for contract claims, but a more specific limitations statute controls when it covers the claim.
Aull v. Cavalcade Pension Plan · filed 1997-12-31(l)(a)
In Colorado there are two different statutes of limitation that could apply, the three year statute of limitations of Colo.Rev.Stat. § 13-80-101(l)(a) for contract claims and the six year statute of limitations of Colo. Rev. Stat. § 13-80-103.5(l)(a) which applies to “all actions to recover a liquidated debt or an unliquidated, determinable amount of money due to the person bringing the action, all actions for the enforcement of rights set forth in an instrument securing the payment of or evidencing any debt, and all actions of replevin to recover the possession of personal property encumbered under any instrument securing any debt.” ... I adopt his reasoning and find that the six year statute of limitations of Colo.Rev.Stat. § 13-80-103.5 applies to this action.Read the full opinion on CourtListener →
Section 13-80-101(1)(f) permits a three-year limitation period for claims for breach of fiduciary duty and aiding and abetting breach of fiduciary duty.
Smith Ex Rel. Boston v. Arthur Andersen LLP · filed 2001-12-06(1)(f)
Accordingly, for the purposes of determining dismissal based on statute of limitations, this Court will apply Colorado law. ... Typically, in Colorado, a cause of action for negligence must be filed within two years after the cause of action accrues or in the case of breach of fiduciary duty and aiding and abetting breach of fiduciary duty, a three year limitation is permitted. Colo.Rev.Stat. § 13-80-101(l)(f). However, Colorado subscribes to the general discovery rule, which renders the statute of limitations somewhat flexible.Read the full opinion on CourtListener →
Section 13-80-101(l)(a) supplies a three-year limitations period for contract actions.
Frymire v. Ampex Corp. · filed 1995-07-19(l)(a)
This, however, does not end the analysis. We must still decide whether the district court erred as a matter of law in applying Colorado’s three-year limitations period for contract actions to Plaintiffs’ WARN claim. Based on the Supreme Court’s recent decision in North Star Steel Co. v. Thomas, — U.S. —, 115 S.Ct. 1927, 132 L.Ed.2d 27 (1995), we conclude that the district court committed no error. ... For the foregoing reasons, we affirm the district court’s application of Colorado’s three-year contract claim limitations period to WARN and reject Ampex’s contention that Plaintiffs’ WARN claim is time-barred.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) provides a three-year limitations period for fraud claims in Colorado, applied with Colorado’s discovery rule so accrual is postponed until the plaintiff discovers or reasonably should have discovered the injury and its likely wrongful cause.
Putzier v. Ace Hardware Corp. · filed 2014-06-25(1)(c)
In Colorado, Lorenz and Arvada Ace had three years. Colo.Rev. Stat. § 13-80-101(i )(c). All three states— Washington, Texas, and Colorado—allow for tolling of the limitations period by the discovery rule so that a fraud claim does not accrue until a plaintiff has discovered his claim. ... The discovery rule tolls the statute of limitations for fraud until a plaintiff discovers or reasonably should have discovered that he has been injured and that his injury was likely caused by the wrongful acts of another. ... For the purposes of this motion to dismiss, therefore, the discovery rule tolled the statutes of limitations for Plaintiffs’ claims of fraudulent inducement and fraud until sometime in the spring of 2011. Although Plaintiffs do not indicate the precise date when they became aware of their causes of action for fraudulent inducement and fraud, the gap between the spring of 2011 and January 6, 2012, when this action was filed, is less than a year and is well within Washington’s and Colorado’s three-year and Texas’s four-year statutes of limitations. The Court thus declines to dismiss this action as time-barred.Read the full opinion on CourtListener →
Section 13-80-101(l)(a) provides a three-year limitations period for contract claims, including claims based on an express contractual obligation.
Insurance Co. of North America v. Aspen Alps Condominium Ass'n · filed 1996-02-22(l)(a)
Therefore, I find that this claim was timely commenced within the three year limitations period for contracts prescribed by Colo.Rev. Stat. § 13-80-101(l)(a) (1987 & Supp.1995).Read the full opinion on CourtListener →
Section 13-80-101’s three-year period for contract actions yields to § 13-80-103.5 when the action seeks a determinable amount of money owed under a contract.
Trustees of Carpenters & Millwrights Health Benefit Trust Fund v. Lillard & Clark Construction Co. · filed 1990-11-27(1)(a)
Furthermore, a statute of limitations such as § 13-80-103.5 which specifically addresses a particular class of cases controls over a more general statute of limitations such as § 13-80-101.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) excepts contract claims for a liquidated debt or determinable amount of money from its three-year limit; those claims have a six-year limit under § 13-80-103.5(1)(a).
Fishburn v. City of Colorado Springs · filed 1995-11-09(1)(a)
Under the express exception in § 13-80-101(l)(a) for such actions, if plaintiffs’ claim is for a liquidated debt or a determinable amount of money, § 13-80-103.5(l)(a) applies even though it is an action based on a contract.Read the full opinion on CourtListener →
Section 13-80-101(1)(a)’s three-year period for contract actions does not apply when a more specific limitations statute governs a claim to enforce rights under a real-property agreement.
San Juan Basin Consortium, Ltd. v. Enervest San Juan Acquisition Ltd. Partnership · filed 1999-10-18(1)(a)
However, I disagree that C.R.S. § 13-80-101 is the correct limitations period to apply to this claim. ... The limitations period that EnerVest relies upon is not the most specific in light of the facts of this case. Instead, C.R.S. § 38-41-116, although never mentioned by either of the parties, is the most applicable statute. Therefore, EnerVest’s reliance on the three year limitations period for general contract actions is misplaced.Read the full opinion on CourtListener →
Section 13-80-101 requires contract claims to be commenced within three years.
Avedon Engineering, Inc. v. Seatex · filed 2000-09-01(1)(a)
Section 13-80-101 requires that contract claims be commenced within three years. ... Instead, Colorado’s three-year statute of limitations applies.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives a plaintiff three years to bring an insurance contract claim unless an exception in § 13-80-108.5 applies.
Union Pacific Railroad v. Certain Underwriters at Lloyd's, London · filed 2001-11-08(1)(a)
Under the express language of the current statute, the three-year limitation applies unless plaintiff's claims fit under an exception provided in § 13-80-108.5.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives unjust enrichment claims a three-year limitations period.
Luttgen v. Fischer · filed 2005-01-13(1)(a)
A three-year limitations period applies to claims for unjust enrichment.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) provides a general limitations period for common law contract actions, but a specific limitations period controls actions on public works bonds.
Pat's Construction Service, Inc. v. Insurance Co. of the West · filed 2005-12-01(1)(a)
Section 13-80-101(l)(a), C.R.S.2005, is a general and broad provision that encompasses all common law contract actions, while § 38-26-105 is a specific provision that applies to actions to recover payment under a public works contractor’s performance bond. Sections 38-26-105 and 38-26-107 specifically apply to the construction project that is the subject of Pat’s Construction’s action. Therefore, the specific statute of limitations provision in § 38-26-105 controls over the general civil action provision in § 13-80-101(l)(a).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives quantum meruit claims a three-year limitations period measured from accrual.
Hannon Law Firm, LLC v. Melat, Pressman & Higbie, LLP · filed 2011-03-03(1)(a)
The statute of limitations applicable to a quantum meruit claim is three years from the date the claim accrues. § 13-80-101(1)(a), C.R.S.2010; Rotenberg v. Richards, 899 P.2d 365, 368 (Colo.App.1995).Read the full opinion on CourtListener →
Section 13-80-101 requires a breach of warranty action to be brought within three years after the claim accrues.
Broomfield Senior Living Owner, LLC v. R.G. Brinkmann Co · filed 2017-03-09
Once a breach of warranty claim accrues, any action must be brought within three years under § 13-80-101, C.R.S. 2016.Read the full opinion on CourtListener →
The three-year limit for contract actions does not apply to a claim for determinable royalties when the requested records serve to establish the amount owed; the six-year limit applies.
Hildebrand v. Wilmar Corporation · filed 2020-10-20(1)(a)
Defendant contends the three-year statute of limitations under C.R.S. § 13-80-101 applies to such alleged breaches. The Court finds otherwise. ... To make its three-year vs. six-year argument, Defendant attempts to parse out the allegations but at bottom this action is to recover the royalties which are allegedly owed under the Agreement; the documents which Plaintiff concomitantly seeks to obtain are those which would allow him to determine how much is owed under the Agreement and whether he has in fact been fully paid. Such royalties are either liquidated or determinable. ... Accordingly, the Court finds the six-year statute of limitations controls.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) sets a three-year limit for contract actions, except those covered by a specific six-year limitations provision.
Box Elder Kids, LLC v. Anadarko E & P Onshore, LLC · filed 2024-08-21(1)(a)
Section 13-80-101(1)(a), C.R.S. 2023, provides a three-year limitation period for “all contract actions” but includes an exception for “those specific kinds of contract actions singled out for a six-year limitation period elsewhere.” ... The Court concludes, over no apparent objection from the parties,3 that the claimed underpayments at issue here are unliquidated, determinable amounts of money, and that the six-year statute of limitations period therefore applies to Plaintiffs’ breach of contract claim.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives a plaintiff three years after accrual to bring a breach of contract claim.
Conte v. Frazar · filed 2025-10-09(1)(a)
Breach of contract claims expired by the end of June 1995, which is three years after the cause of action accrued, see § 13-80-101(1)(a).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives a contract claim a three-year limitations period when the amount owed is not determinable under the exception in section 13-80-103.5(1)(a).
Creative v. LeRoux · filed 2025-11-20(1)(a)
Thus, the Geigle lawyers’ counterclaim was subject to section 13-80-101(1)(a)’s three-year statute of limitations because it didn’t seek to recover a determinable amount of money owed.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) sets a three-year limitations period for breach-of-contract claims; a claim filed within that period is timely at the pleading stage.
Shat Acres Higland Cattle, LLC v. American Highland Cattle Association · filed 2024-11-25(1)(a)
Hence, the contract claims are timely under both Vermont’s six-year and Colorado’s three-year statutes of limitations, and the Court will therefore not dismiss the contract claims based on timeliness at the pleading stage.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives contract claims three years from accrual, subject to a six-year exception for claims seeking a liquidated debt or determinable amount.
Three Circle v. Public Service · filed 2025-02-27(1)(a)
Section 13-80-101(1)(a), C.R.S. 2024, provides that contract claims must be brought within three years after the claim accrues. However, section 13-80-103.5(1)(a), C.R.S. 2024, contains an exception.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) applies a three-year limitations period to a request for declaratory relief concerning contractual rights.
Omer A v. Nsirat A · filed 2025-05-08(1)(a)
Second, because the Omers seek a declaration of their rights under a contract, the limitations period of three years in section 13-80-101(1)(a) controls.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) imposes a three-year limitations period on breach-of-contract claims.
Sandoval v. Archdiocese of Denver · filed 2000-07-06(1)(a)
Moreover, the claims raised by plaintiff in her second amended complaint were already barred at that time by the applicable statutes of limitations. See § 18-80-101(1)(F), C.R.S. 1999 (claim for breach of fiduciary duty subject to three-year limitation); § 13-80-101(1)(a), C.R.S.1999 (claim for breach of contract subject to three-year limitation); § 13-80-102, C.R.8.1999 (claims brought under the federal statutes are subject to a two-year limitations period).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) sets a three-year limitations period for Colorado breach of contract claims.
Sipple v. Zions Bancorporation, N.A. · filed 2022-03-28(1)(a)
Breach of contract claims in Colorado are subject to a three (3) year ... limitations period. See C.R.S. § 13-80-101(1)(a). ... A more appropriate estimate uses six years of data for the Nevada, Arizona, and Utah divisions, four years of data for the Texas and California divisions, and three years of data for the Colorado division, which results in approximately $4,336,935.93.Read the full opinion on CourtListener →
Section 13–80–101(1)(a) gives a breach of contract claim a three-year limitations period when the amount owed is not determinable.
Timnath Trail v. Town of Timnath · filed 2025-06-26(1)(a)
We agree with the district court’s conclusion that the school fees were not determinable and, therefore, subject to the three-year limitations period in section 13–80–101(1)(a).Read the full opinion on CourtListener →
Three-year limitation for motor vehicle bodily injury actions
Subsection (1)(n) provides a three-year limitations period for bodily-injury actions arising from the use or operation of a motor vehicle; filing within that period preserves the underlying claim for the uninsured-motorist statute’s grace period.
Helm v. Progressive Direct Insurance Company · filed 2024-03-25(1)(n)
Plaintiff “preserved” her claim by filing suit against Ms. Young within three years, i.e., the time limit specified in Colo. Rev. Stat. § 13-80-101(1)(n) for bodily injury actions arising from use or operation of a motor vehicle. Colo. Rev. Stat. § 13-80-107.5(1)(a) (incorporating Colo. Rev. Stat. § 13-80-101(1)(n)).Read the full opinion on CourtListener →
Section 13-80-101(1)(c) imposes a three-year limitations period on fraud claims.
Ditto v. Sanofi S.A. · filed 2024-04-09(1)(c)
The parties agree that Colorado law governs this dispute. They also agree on the applicable limitation periods. ECF No. 52 at 10–12; ECF No. 53 at 9. Plaintiff’s negligence and strict liability claims are subject to Colorado’s two-year statute of limitations for product liability claims, Colo. Rev. Stat. § 13-80-106(1), and their fraud claims are subject to a three-year statute of limitations. Colo. Rev. Stat. § 13-80-101(1)(c). ... Because Plaintiffs did not file their lawsuit until September 2017—long after the three-year statute of limitations expired on their fraud claims—their claims are time-barred.Read the full opinion on CourtListener →
Section 13-80-101(1)(h) imposes a three-year limitations period on civil theft claims because they are actions for taking property.
Commissiong v. Center at Lincoln, LLC, The · filed 2025-03-25(1)(h)
Comparing the language of § 13-80-102(1)(a) and § 13-80-101(1)(h), the Court finds that § 13-80-101(1)(h) more clearly governs Ms. Commissiong’s civil theft claim. ... Accordingly, the Court finds that a three-year statute of limitations governs her civil theft claim.Read the full opinion on CourtListener →
Section 13-80-101(1)(c) imposes a three-year limitations period on fraud claims, running from when the cause of action accrues.
Labonte · filed 2026-02-10(1)(c)
“Under Colorado law, the statute[ ] of limitations for fraud ... [is] three years after the cause of action accrues.” (citing Colo. Rev. Stat. § 13-80-101(1)(c)).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) supplies a three-year limitations period for quantum-meruit claims not subject to the six-year exception in section 13-80-103.5.
Torres-Vallejo v. CreativExteriors Inc. · filed 2016-11-23(1)(a)
will be limited by the 3-year statute of limitations provided by § 13-80-101(l)(a).Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives claims sounding in contract a three-year limitations period, running from discovery of the breach or when it should have been discovered with reasonable diligence.
Guion (PS) v. Stancil · filed 2024-09-09(1)(a)
Under Colorado law, claims sounding in contract are subject to a three-year statute of limitations. Colo. Rev. Stat. § 13-80-101(1)(a).Read the full opinion on CourtListener →
Section 13-80-101(1)(c) imposes a three-year limitations period on fraud claims.
Trueforce Global Services, Inc. v. Trueffect, Inc. · filed 2023-07-19(1)(c)
Respectfully, the Court disagrees that Mr. Sala is entitled to summary judgment based on a statute of limitations defense. ... This Court may not weigh evidence, judge credibility, or rule on the merits of the Parties’ competing theories about what Trueforce knew, and when Trueforce knew or should have known it, to resolve their disagreement about the claim’s accrual and Trueforce’s diligence. ... Against this record, this Court concludes that genuine issues of material fact pervade the question whether Trueforce exercised reasonable diligence such that the claim is timely.Read the full opinion on CourtListener →
Section 13-80-101(1) requires contract actions to be commenced within three years after the cause of action accrues.
Pagosa Springs Investments v. Sivers · filed 1994-11-03(1)
Section 13-80-101(1), C.R.S. (1987 Repl. Vol. 6A) requires that all contract actions be commenced within three years after the cause of action accrues.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives a claim arising from nonperformance of contractual duties a three-year limitation period.
Farmers Insurance Exchange v. American Manufacturers Mutual Insurance Co. · filed 1995-04-27(1)(a)
Thus, because the cause of action arose out of a nonperformance of contractual duties, it accrued at the latest on April 30, 1988, when Farmers first expended monies to defend the named driver. The court did not err, therefore, in concluding that the relevant statute of limitation had run because Farmers’ claim had accrued nearly four years prior to its filing this lawsuit in March 1992.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) generally gives contract actions three years, including claims for compensation based on quantum meruit, but does not govern claims subject to the six-year period in § 13-80-103.5.
Rotenberg v. Richards · filed 1995-06-15(1)(a)
Section 13-80-101(l)(a) is a statute that generally establishes a three-year limitations period for contract actions. By its express terms, however, it is not applicable to those actions, whether they are based on alleged contract breaches or otherwise, that are governed by six-year period established by § 13-80-103.5.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives a plaintiff three years to bring a personal injury action arising from an automobile accident, including an action against a sheriff’s department.
Reider v. Dawson · filed 1993-07-26(1)(j)
We agree with plaintiffs. ... We consider this ruling to be dispositive of this appeal. ... Accordingly, because the record reflects that the complaint was filed within three years after the date of the accident, we conclude that it was timely filed.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) allows three years for a bodily injury tort action arising from the plaintiff’s use of a motor vehicle, even when the defendant was not operating one.
Gonzales v. City and County of Denver · filed 2000-04-24(1)(n)(I)
Defendants argue, and the trial court concluded, that the General Assembly actually intended § 13-80-101(l)(n)(I) to apply only when a plaintiffs claimed injury arose out of the alleged tortfeasor’s use or operation of a motor vehicle. We decline to read that limitation into the statute when its plain language does not suggest such an intent.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) gives plaintiffs three years to bring tort actions for bodily injury or property damage arising from the use or operation of a motor vehicle, even when the alleged tortfeasor did not use or operate one.
City and County of Denver v. Gonzales · filed 2001-01-16(1)(n)(I)
We hold that the three-year statute of limitations contained in section 13-80-101(1)(n)(I) applies when the plaintiff's bodily injury or property damage arises from the use or operation of a motor vehicle, whether or not the alleged tortfeasor used or operated a motor vehicle.Read the full opinion on CourtListener →
Section 13-80-101(1)(a) requires contract actions to be commenced within three years after the cause of action accrues.
Bell v. Land Title Guarantee Co · filed 2018-05-17(1)(a)
A plaintiff must commence tort actions within two years from the date the cause of action accrues, see § 13-80-102(1)(a), C.R.S. 2017, and contract actions within three years from the date the cause of action accrues, see § 13-80-101(1)(a), C.R.S. 2017.Read the full opinion on CourtListener →
Section 13-80-101(1)(n) allows three years after accrual to bring a motor vehicle tort action against a driver, other than a wrongful death action.
Rider v. State Farm Mutual Automobile Insurance Co. · filed 2009-02-05(1)(n)
Tort actions against a driver arising out of the use or operation of a motor vehicle, other than wrongful death actions, are governed by section 13-80-101(l)(n), C.R.S.2008, and can be brought within three years after the cause of action accrues.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) applies to motor vehicle tort actions for bodily injury or property damage, but does not govern wrongful death actions.
ABERKALNS v. Blake · filed 2009-05-15(1)(n)(I)
On its face, subsection 101(l)(n)(I) applies to “tort actions,” whereas C.R.S. § 13-80-102(l)(d) applies to “actions for wrongful death.”Read the full opinion on CourtListener →
Section 13-80-101(1)(a) gives three years to bring a contract action and supplies the limitations period for a non-hybrid Section 301 collective bargaining agreement claim.
United Food and Commercial Workers International Union, Local No. 7, AFL-CIO v. Kaiser Foundation Health Plan of Colorado · filed 2024-07-09(1)(a)
Second, Colorado Revised Statutes § 13-80-101(1)(a) provides that “[a]ll contract actions” “shall be commenced within three years after the cause of action accrues.” ... Having thoroughly considered the parties’ arguments, the Court finds that Colorado’s three-year statute of limitations for contract actions applies to the Union’s claim here.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) gives a person injured in a motor vehicle accident three years from the accident to bring suit.
Mohammadi v. Kinslow · filed 2022-09-08(1)(n)(I)
In general, a person injured in a motor vehicle accident must bring suit within three years of the date of the accident. See §§ 13-80-101(1)(n)(I), -108(1), C.R.S. 2021.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I)'s three-year limit covers bodily-injury tort claims arising while a hired mechanic inspects or repairs a motor vehicle.
Nesjan v. J & A Distributing, Inc. · filed 2025-10-02(1)(n)(I)
We consider the meaning of the phrase “use . . . of a motor vehicle” in section 13-80-101(1)(n)(I), and we hold that this phrase encompasses a person who was hired to inspect and repair a motor vehicle and who sustained bodily injuries during performance of those maintenance-related activities.Read the full opinion on CourtListener →
Section 13-80-101(1)(n)(I) sets a three-year limit for motor vehicle injury claims; amended complaints filed after that period are untimely if they do not relate back.
Currier v. Sutherland · filed 2009-10-19(1)(n)(I)
Because the amended complaints, filed long after the statute of limitations had expired, do not relate back to the original complaint, they cannot be considered timely filed. The trial court therefore correctly held that Currier and Schultg's claims were barred by the statute of limitations.Read the full opinion on CourtListener →
Applicability of statute of limitations to statutory wage claims
Section 13-80-101 does not supply the limitations period for statutory Wage Order claims because those claims are neither contractual nor tort claims.
Sobolewski v. Boselli & Sons LLC · filed 2018-09-21
The Court must, therefore, look to Colorado's general statutes of limitation for an answer. Plaintiff's wage period and meal period claims arise by statute-the Wage Order. Thus, these claims are neither based in contract nor tort, making inapplicable the general limitations on actions ... Colo. Rev. Stat. § 13-80-101 ... (3 years for contract actions) and ... Colo. Rev. Stat. § 13-80-102 ... (2 years for tort actions).Read the full opinion on CourtListener →
Limitations period for fraudulent-transfer actions
Section 13-80-101(1)(c) supplies a three-year limitations period for the relevant fraudulent-transfer claim.
Lewis v. Delap · filed 1997-08-12(1)(c)
The parties agree that the relevant statute of limitations is three years. See Colo. Rev. Stat. § 13-80-101(1)(c) (1987). A cause of action for fraudulent transfer claims under § 38-10-117 must be filed within three years after the aggrieved party discovers the facts or should have discovered the facts by an exercise of reasonable diligence.Read the full opinion on CourtListener →
Section 13-80-101(1)(c)'s three-year period for fraud causes of action does not bar asserting fraud as an affirmative defense.
Sulley v. Taylor · filed 2020-11-20(1)(c)
The statute of limitation is not a bar to a claim asserted as a defense.Read the full opinion on CourtListener →
For tort actions for bodily injury or property damage arising from the use or operation of a motor vehicle, the statute provides a three-year limitations period, even when the defendant did not use or operate the vehicle, so long as the injury has some causal connection to that use or operation.
Dominguez · filed 2026-06-12(1)(n)(I)
Applying Gonzales, the Court respectfully concludes that Claims III and IV satisfy § 13-80-101(1)(n)(l) as arising out of the use or operation of a motor vehicle.Read the full opinion on CourtListener →
Section 13-80-101 provides a three-year limitations period for fraudulent-conveyance actions.
Larsen v. Munoz (In Re Munoz) · filed 1990-03-08
Colorado’s statute of limitations with respect to fraudulent conveyance actions is three years. Colo.Rev.Stat. § 13-80-101 (1987).Read the full opinion on CourtListener →
Section 13-80-101(l)(c) imposes a three-year limitations period on actions for fraud, misrepresentation, concealment, or deceit, including the fraudulent-conveyance claim at issue.
Rosania v. Haligas (In Re Dry Wall Supply, Inc.) · filed 1990-03-16(l)(c)
Under this interpretation, since the fraudulent transfer occurred on February 17, 1983, under Colorado state law, an action for fraudulent conveyance must be commenced within three years, or before February 17, 1986. See Colo.Rev.Stat. § 13-80-101(l)(c) (1987) (establishing a three-year statute of limitations for actions for fraud, misrepresentation, concealment or deceit).Read the full opinion on CourtListener →
Section 13-80-101(c) provides a three-year limitations period for a fraudulent-conveyance action that, absent actual notice of the transfer, begins when the general creditor obtains a judgment against the debtor.
Hill v. Walden (In re walden) · filed 1997-04-04(c)
Therefore, the statute of limitations on Donna Grimshaw’s § 38-10-117 lawsuit began running on August 19, 1993, the day that she acquired a judgment against Mr. Walden in Jefferson County, Colorado District Court (93-CV-1380). Ms. Grimshaw filed her § 38-10-117 suit on September 22, 1994 (94-CV-1766), which occurred within the three year period prescribed by § 13-80-101(c). Therefore, the Trustee cannot be barred from bringing an action in her shoes by virtue of an expired statute of limitations.Read the full opinion on CourtListener →
Accrual of indemnity claims
An insurer-indemnity claim accrues when a judgment against the insured first permits the claim to be brought; an action filed within three years of that judgment is timely.
Flatiron Paving Co. of Boulder v. Great Southwest Fire Insurance Co. · filed 1990-10-25(1)(a)
The judgment against Whitlock is dated November 19, 1984. It was not until then that the insured or its assignee could have brought a failure to indemnify action against Southwest. As third-party beneficiary, Flatiron had not sustained any damages until it had obtained a judgment against Whitlock from whom it was unable to collect. Flatiron’s action against Southwest was commenced May 14, 1987, well within the three-year period following the accrual of its claims. Therefore, whether the three-year or a longer period statute applies, this action was not time barred.Read the full opinion on CourtListener →
For a breach of warranty claim involving a grantee who never possessed the land and the government’s paramount title, the limitations period begins when the grantee knew or should have known of that title.
Upton v. Griffitts · filed 1992-04-23
Hence, since plaintiffs suffered no damages until learning of the adverse government claim, the statute of limitations did not begin to run until 1986, when plaintiffs knew, or should have known, of the paramount title.Read the full opinion on CourtListener →
The three-year limitations period for an underinsured motorist contract claim begins upon an event constituting a breach by the insurer.
State Farm Mutual Auto Insurance Co. v. Springle · filed 1993-10-07(1)(a)
In so holding, the court declared that, by 1990, the overwhelming majority of courts which had addressed this question had concluded that the limitations period began to run upon some event constituting a breach by the insurer. We agree that this is the better rule and adopt it here as our own.Read the full opinion on CourtListener →
The three-year limitations period for a contract claim begins when the claim arises; a claim for breach of an escrow agreement arose when a party objected to a disbursement request.
US Bank v. 355 Lake · filed 2025-12-11(1)(a)
The trustee’s claim for breach of the escrow agreement did not come into existence until 335 Lake submitted its objection on April 28, 2022. ... The trustee asserts that the three-year limitation period for all contract actions found in section 13-80-101(1)(a), C.R.S. 2025, governed its claim for breach of the escrow agreement. That limitation period did not start running until April 2022 — less than six months before the trustee asserted the trustee’s claims.Read the full opinion on CourtListener →
Limitations period for consumer protection claims
Former § 13-80-101(1)(c) supplies the limitations period for a CCPA claim that accrued before the CCPA gained its own limitations provision.
Robinson v. Lynmar Racquet Club, Inc. · filed 1993-03-11(1)(c)
Her action, therefore, accrued in 1989, and, having been filed in December 1989, was timely brought under either § 6-1-115 or the former statute, § 13-80-101(l)(c), C.R.S. (1987 Repl.Vol. 6A).Read the full opinion on CourtListener →
Applicability to C.R.C.P. 60(b) motions
Section 13-80-101’s three-year limitation does not govern a motion to annul an adoption filed under C.R.C.P. 60(b)(2); the rule supplies the deadline.
In Re the Adoption of P.H.A. · filed 1995-06-01(1)(e)
We reject father’s contention that his motion for annulment was subject to the three-year statute of limitations set forth in § 13-80-101(l)(e), C.R.S. (1987 Repl.Vol.6A). As discussed above, the motion was filed pursuant to C.R.C.P. 60(b)(2) and thus, was subject to the time restrictions set forth in that rule.Read the full opinion on CourtListener →
Breach of fiduciary duty—three-year limitation
Section 13-80-101(1)(f) gives a claim for aiding and abetting breach of fiduciary duty a three-year limitations period.
Sender v. Porter (In Re Porter McLeod, Inc.) · filed 1999-03-17(1)(f)
Having determined that claim twelve is not duplicative of claim eleven for legal malpractice, I conclude that the statute of limitations applicable to claim twelve is three years.Read the full opinion on CourtListener →
Section 13-80-101(1)(f) sets a three-year limitations period for breach of fiduciary duty claims between corporate directors and shareholders.
Polk v. Hergert Land & Cattle Co. · filed 2000-06-22(1)(f)
An action for breach of fiduciary duty between directors and shareholders is subject to the three-year statute of limitations set out in § 13-80-101(1)(f), C.R.S.1999.Read the full opinion on CourtListener →
Section 13-80-101(f) provides a three-year limitations period for breach-of-fiduciary-duty claims.
Pound v. Fletter · filed 2001-11-23(f)
We also reject plaintiff's contention that the court erred in applying the three-year statute of limitations in § 13-80-101(f), C.R.S.2001, rather than the six-year period in § 13-80-103.5, C.R.S.2001. ... As no contract exists between plaintiff and defendant Fletter, we determine that the district court properly applied the three-year statute of limitations.Read the full opinion on CourtListener →
A breach of contract claim must be filed within three years after it accrues; when the evidence permits disagreement about when the breach was discovered, the limitations defense may be resolved by the jury.
International Network, Inc. v. Woodard · filed 2017-04-06(1)(a)
A breach of contract claim “shall be commenced within three years after the cause of action accrues.” § 13-80-101(1)(a), C.R.S. 2016. ... Accordingly, the court did not err in denying seller’s motions for directed verdict and judgment notwithstanding the verdict based on the statute of limitations.Read the full opinion on CourtListener →
Section 13-80-101(1)(f) requires a breach of fiduciary duty claim to be brought within three years of accrual.
Prospect Dev. Co. v. Holland & Knight, LLP · filed 2018-07-26(1)(f)
Prospect was required to bring the professional negligence claim within two years of its accrual, section 13-80-102(1)(a), C.R.S. 2017, and the breach of fiduciary duty claim within three years of its accrual, section 13-80-101(1)(f), C.R.S. 2017.Read the full opinion on CourtListener →
Section 13-80-101(1)(f) sets a three-year limitations period for breach of fiduciary duty claims.
Tisch v. Tisch · filed 2019-03-21(1)(f)
Therefore, we agree with the trial court that the timing of the Tisch siblings’ knowledge of their injuries was not subject to reasonable debate. And by filing their complaint on April 29, 2016, they were well within the relevant two- and three-year statute of limitations periods for both civil theft and breach of fiduciary duty.Read the full opinion on CourtListener →
Section 13-80-101(f) does not bar a breach-of-fiduciary-duty claim at the pleading stage when the complaint alleges ongoing breaches and delayed reasonable discovery.
Estate of Jon L. Bogue, The v. Adams · filed 2019-08-01(f)
Plaintiffs have not pled themselves out of court. The Amended Complaint alleges ongoing breaches of fiduciary duties by Defendants in connection with their management of Bogue’s investment accounts. ... The Amended Complaint further alleges that Defendants’ breaches of fiduciary duty could not reasonably have been discovered until June 7, 2016, when the Colorado Securities Division entered its Consent Order finding violations by Mr. Adams and Choice Investment Management. ... They suffice to withstand a motion to dismiss.Read the full opinion on CourtListener →
Limitations period for underinsured motorist benefits
Section 13-80-101 provides a three-year limitations period for UIM benefit claims arising from accidents before July 1, 1994.
Brown v. American Family Insurance Group · filed 1999-04-01
The statute of limitations for UIM benefit claims on accidents occurring prior to July 1,1994, is the three-year general statute of limitations found in § 13-80-101.Read the full opinion on CourtListener →
Three-year limit for replevin and conversion
Section 13-80-101(1)(h) requires actions for replevin or for taking, detaining, or converting goods or chattels to be commenced within three years after the cause of action accrues.
In Re Estate of Krotiuk · filed 2000-05-11(1)(h)
Actions of replevin or for taking, detaining, or converting goods or chattels must be commenced within three years after the cause of action accrues. Section 13-80-101(1)(h), C.R.S.1999. ... Because he did not file the claim for return of the rugs until 1997, two years after the statute of limitations had run, we perceive no error by the trial court in granting partial summary judgment for the estate as to that part of the claim.Read the full opinion on CourtListener →
Tolling under the repair doctrine
The three-year limitations period for UCC claims may be tolled under the repair doctrine for past repair costs while the seller continues trying to fix the goods.
Curragh Queensland Mining Ltd. v. Dresser Industries, Inc. · filed 2002-10-04(1)(a)
We reject Seller's contention that the repair doctrine cannot apply to claims for past repair damages. Requiring a buyer to institute suit for past repairs while a seller is still attempting to make repairs would be inconsistent with the policy underlying the repair doctrine, which favors the voluntary settlement of disputes without unnecessary litigation.Read the full opinion on CourtListener →
Contractual shortening of limitations period
Section 13-80-101(1)(a) sets a three-year limitations period for contract suits but does not prohibit parties from agreeing to a shorter period.
Grant Family Farms, Inc. v. Colorado Farm Bureau Mutual Insurance Co. · filed 2006-11-02(1)(a)
Section 13-80-101(1)(a) contains no language prohibiting contractually shortening the three-year limitations period. Therefore, we agree with the trial court that the contractual limitations period is not "in conflict" with § 13-80-101(1)(a).Read the full opinion on CourtListener →
Collection of judgments
Section 13-80-101(1)(k)’s three-year limit does not bar an action to collect on a previously obtained judgment through quiet title and foreclosure.
Independent Bank v. Pandy · filed 2015-01-15(1)(k)
First, contrary to the Pandys’ assertions, we conclude that the three-year statute of limitations in section 13—80—101 (l)(k) is inapplicable to the Bank’s complaint. Although at this point section 13—80—101(l)(k) might prevent the Bank from teinging a civil action to alter the record title to the C Lazy U Homesteads, it does not preclude the Bank from collecting on its previously obtained judgment.Read the full opinion on CourtListener →
Section 13-80-101(1)(k) did not bar an action to enforce a previously obtained and properly domesticated judgment against the debtor’s interest in a co-settled revocable trust.
Pandy v. Independent Bank · filed 2016-06-20(1)(k)
Accordingly, the Bank could properly ... seek to enforce its judgment against Mr. Pandy in this case, and its action was not barred by the statute of limitations set forth in section 13-80-101(1)(k).Read the full opinion on CourtListener →
Void deeds
Section 13-80-101(1)'s limitation periods do not apply to a claim that a deed is void because the grantor lacked authority to convey the property.
Marken v. Knez · filed 2025-03-06(1)
Instead, the statute of limitations does not apply because, when a grantor lacks the authority to convey the property, there is no legally cognizable transaction that would start the limitations period running.Read the full opinion on CourtListener →
Accrual of enhanced PIP claims
Law changed since Same change as noted above.
Section 13-80-101(1)(j) gives an insured three years to bring a claim for enhanced PIP benefits, measured from when the insured knew or should have known those benefits had not been offered.
Nehls v. Farmers Alliance Mutual Insurance · filed 2007-07-10(1)(j)
M s. Nehl has provided no convincing reasons for us to depart from the teachings of Nelson on the accrual date for her type of claim. Accordingly, the three-year statute of limitations expired four years before M s. Nehl filed suit.Read the full opinion on CourtListener →
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