Colorado defense costs reimbursement

Under Colorado law, insurer which obtains judicial declaration of no duty to defend is entitled to seek reimbursement of costs incurred in defending insured where insured accepts without objection insurer’s reservation of right to do so. Valley Forge Ins. Co. v. Health Care Management Partners, Ltd., No. 09-1251 (10^th Cir. Aug. 16, 2010).