Supreme Court of Colorado

Milton Michael Trujillo, Insurance Producer With Bail Bond Authority, License No. 60267 v. Colorado Division Of…

March 17, 20142014 Colo. LEXIS 160

Summary

The court held that the statutory fiduciary-duty provision for unearned premiums owed to insureds did not apply to the bail-bond transaction because Espinoza was not an insured under the statute. Although several unappealed violations independently could support discipline, the court could not determine whether the Commissioner would have imposed the same sanction without relying on the invalid fiduciary-duty theory. The court therefore reversed and remanded for reconsideration of the sanction. No separate opinions were provided.