England v. Amerigas Propane and Indemnity Insurance Company of North America

Citations

• 2017 CO 55
• 395 P.3d 766
• 2017 WL 2333118

Syllabus

Workers' Compensation—Mutual Mistake of Material Fact—Colorado Workers' Compensation Act. In this case, the Supreme Court considered whether a provision of the mandatory form settlement document promulgated by the Director of the Division of Workers' Compensation waives an injured employee's statutory right under CRS § 8-43-204(1) to reopen a settlement based on a mutual mistake of material fact. The Court concluded that it does not because provisions of the form document must yield to statutory rights. Accordingly, the Court reversed the judgment of the Court of Appeals.