In Re Lindsay Winninger, an Individual and Sports Rehab Consulting LLC, a Colorado Limited Liability Company V…

Summary

The court held that the civil-theft statute applies only to theft under the general theft statute and does not authorize a civil claim based on the separate crime of stealing medical records or medical information. Because the defendants’ civil-theft claim rested on the medical-records statute, they lacked standing to pursue it, and the court made its rule to show cause absolute. The court therefore did not reach whether the claim was independently barred by the medical-records statute’s separate limitation.