Supreme Court of Colorado

Pinnacol Assurance, Petitioner v. Norma Patricia Hoff; Hernan Hernandez; Alliance Construction & Restoration, Inc…

June 27, 20162016 Colo. LEXIS 678

Summary

The court held that Pinnacol had no contractual or statutory duty to notify Alliance, a non-insured certificate holder, that MDR's workers' compensation policy had been cancelled. The certificate incorporated the policy's notice provisions, which required notice only to MDR, and the Workers' Compensation Act did not extend that obligation to certificate holders. Because no promise of notice existed, Hoff's promissory-estoppel claim failed, and the court reversed the court of appeals. Justice Gabriel concurred while urging legislative clarification, and Justice Coats, joined by the Chief Justice and Justice Eid, would have held that the certificate triggered statutory notice and continued coverage.