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

Summary

The court held that Pinnacol had no contractual or statutory duty to notify Alliance, a certificate holder and statutory employer, that MDR’s workers’ compensation policy had been cancelled. Because the certificate did not promise cancellation notice and the Workers’ Compensation Act did not impose such a requirement, Hoff could not establish the promise element of promissory estoppel. The court therefore reversed the court of appeals. Justice Gabriel concurred while urging legislative clarification, and Justice Coats, joined by Chief Justice Rice and Justice Eid, dissented and would have treated the certificate as requiring continued coverage absent notice.