Steven Plitt, Expert Witness Steven Plitt, Expert Witness
Insurance Bad Faith Claim Handling Expert Serving Clients Nationwide

Colorado Supreme Court Rejects The Use Of Extrinsic Evidence To Create Ambiguity In An Insurance Contract

In American Family Mut. Ins. Co. v. Hansen, 2016 CO 46, 275 P.3d 115 (Colo. 2016), the Colorado Supreme Court found that when a discrepancy exists between the policy declarations page and an extrinsic lienholder statement regarding who was an insured, the discrepancy did not create an ambiguity because the ambiguity can only be used under Colorado law to determine whether an ambiguity exists within the four-corners of the insurance contract itself and ambiguity could not be created by an extrinsic document which was not part of the insurance contract. For ambiguity to exist, it must appear in the four-corners of the document before extrinsic evidence could be considered. Extrinsic evidence could only be used as an aide in ascertaining the intent of the parties once an ambiguity was found.

Steven Plitt is an accomplished author and expert witness, and has been a licensed attorney for 33 years. During his career, he has reviewed and analyzed more than 6,000 claim files from 100 different insurance companies. Based in Phoenix, Arizona, he serves as counselor and expert for insurance coverage and bad faith claims nationwide. For more information or to set up an appointment, please visit his website at 

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