Two companion Colorado Court of Appeals decisions delivered appellate wins for FMG’s insurance broker clients, affirming summary judgment and reinforcing key limits on broker liability. In Mayfield v. DeLaCroix, the Court held that an agent owes no…
Two companion Colorado Court of Appeals decisions delivered appellate wins for FMG’s insurance broker clients, affirming summary judgment and reinforcing key limits on broker liability.
In Mayfield v. DeLaCroix, the Court held that an agent owes no duty for a later-renewed policy she neither placed nor serviced, rejected negligent misrepresentation claims where policy language contradicted alleged oral assurances, and declined to find any fiduciary or “special relationship” based on routine agent conduct.
In Wyss v. Campbell, the Court reaffirmed that agents owe a duty of reasonable care—not an obligation to recommend higher limits or ensure complete protection—and rejected attempts to impose heightened duties. The Court also upheld judgment for the insurer on reformation and bad faith claims.
Together, these decisions provide strong, practical authority limiting expanded theories of broker and agent liability in Colorado.
Mayfield v. DeLaCroix, Colorado Court of Appeals Case no. 24CA2026; Wyss v. Campbell, Colorado Court of Appeals Case nos. 24CA1352 & 24CA1845
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