Landmark Case Law and Opinions · 2019. 8. 15. · CR-4 Required Reading Part Two - B Page 1 of 14...

CR-4 Required Reading Part Two - B

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Landmark Case Law and Opinions

I . Supre me Cour t Dec is ion on Pra c t i ce o f Law by B roke rs

Colorado brokers are a l lowed to render serv ices to their c l ients to a greater

degree than are brokers in other states. The pract ic ing real estate broker, of

necessi ty, must work c losely wi th pract ic ing lawyers. Each pract i t ioner zealously

guards the legal f ie ld of h is or her endeavor. In Colorado, a real estate broker

renders serv ice to h is or her c l ient beyond merely procur ing a buyer. Colorado

brokers should fami l iar ize themselves wi th the Colorado Supreme Court ’s

decis ions in the cases of (1 )Conway-Bogue Real ty Investment Co. v . Denver Bar

Assoc ia t ion , (2 ) Ti t le Guaranty Co. v . Denver Bar Associat ion, and (3) Record

Abstract & Ti t le Co. v . Denver Bar Associat ion.

In the case o f Conway-Bogue Real ty Inves tment Co. v. Denver Bar Assoc ia t ion ,

312 P.2d 998 (Colo. 1957), the Colorado Supreme Court addressed whether real

estate brokers should be enjo ined from prepar ing certa in legal documents re lat ing

to and affect ing real estate and the t i t le thereto (such as receipts and opt ions for

purchase, contracts of sa le, deeds, deeds of trust, and leases), and from giv ing

advice to the part ies regarding the legal effect of the documents.

In render ing i ts decis ion, the Colorado Supreme Court stated:

The f i rs t quest ion to be determined is:

Does the preparat ion of receipts and opt ions, deeds, promissory

notes, deeds of trust, mortgages, re leases of encumbrances, leases,

not ice terminat ing tenancies, demands to pay rent or vacate by

complet ing standard and approved pr inted forms, coupled wi th the

giv ing of explanat ion or advice as to the legal effect thereof, const i tu te

the pract ice of law?

This quest ion we answer in the a ff i rmative .

…

The remain ing and most d i f f icu l t quest ion to be determined is:


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Should the defendants as l icensed real esta te brokers (none of whom

are l icensed attorneys) be enjo ined f rom prepar ing in the regular course

of their business the instruments enumerated above, at the requests of

their customers and only in connect ion wi th transact ions involv ing sales of

real estate, loans on real estate or the leasing of rea l estate which

transact ions are being handled by them?

This quest ion we answer in the negative.

…

The test imony shows, and there is no ef for t to refute the same, that

there are three count ies in Colorado that have no lawyers, ten in each of

which there is only one lawyer, seven in each of which there are only two

lawyers; that many persons in var ious areas of the state reside at great

d istances from any lawyer ’s off ice. The test imony shows without

contradict ion that the pract ices sought to be enjo ined are of at least 50

years uninterrupted durat ion; that a vast major i ty of the people of the

state who buy, se l l , encumber and lease real estate have chosen real

estate brokers rather than lawyers to perform the acts herein compla ined

of . Though not contro l l ing, we must make note of the fact that the record is

devoid of ev idence of any instance in which the publ ic or any member

thereof, layman or lawyer has suf fered in jury by reason of the act of any of

the defendants sought to be enjo ined. L ikewise, though not contro l l ing, we

take judic ia l not ice of the fact that the legis lature of the state, composed

of 100 members from al l walks of l i fe and every sect ion of the s tate,

usual ly cal led upon by their const i tuents to adopt leg is lat ion designed to

e l iminate evi ls and protect the publ ic against pract ices contrary to the

publ ic wel fare, has never taken any steps to prevent cont inuat ion of the

a l leged evi l which we are now asked to enjoin.

…

We feel that to grant the in junct ive re l ie f requested, thereby

denying to the publ ic the r ight to conduct real estate transact ions in


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the manner in which they have been transacted for over hal f a century,

wi th apparent sat is fact ion, and requir ing a l l such transact ions to be

conducted through lawyers, would not be in the publ ic in terest. The

advantages, i f any, to be derived by such l imi tat ion are outweighed

by the conveniences now enjoyed by the public in being permit ted to

choose whether their brokers or their lawyers shal l do the acts or

render the serv ice which p la int i f fs seeks to enjoin.

Summary o f Dec is ion on Pra c t i ce o f Law by B ro ke rs

The fo l lowing is an excel lent summary of the case given by John E. Gorsuch,

legal counsel for the Colorado Associat ion of Real tors, quoted from the August

1957 issue of the Colorado Real Estate News:

I t should be kept in mind that the Court sta tes that the pract ices in

quest ion do amount to the pract ice of law. The Court says that i t wi l l

not enjo in real estate brokers from doing these s imple acts, however,

under the c i rcumstances indicated, because of the Court ’s express

bel ie f that the publ ic ’s best in terest wi l l be served by cont inuing the

present pract ice. The present pract ice, however, means the pract ice

shown by the evidence. In other words, the broker ’s act iv i ty is l imi ted

to the fo l lowing circumstances:

1. His off ice must be connected wi th the transact ion as broker.

2. There must be no charge for prepar ing the documents other than the

normal commission.

3. The documents must be prepared on commonly used pr inted, standard,

and approved forms.

I t is c lear from the decis ion that the broker should not, under any

circumstances:

1. Prepare any legal documents as a business, courtesy or favor, for any

transact ion wi th which he is not connected as broker, e i ther wi th or

wi thout pay.


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2. He should not prepare any documents which cannot be proper ly

prepared on the standard and approved printed form.

3. He clear ly should not draw wil ls, contracts , agreements and so forth,

except the init ia l binder contract or other customary agreements of

the type used to b ind the transact ion or sale.

4. In addi t ion, i t would appear in the best in terests of the publ ic and also

in conformity wi th the Court ’s opin ion for the broker to:

a . Always recommend to the purchaser that the t i t le be examined.

b . In form the part ies that each has a r ight to have the papers

prepared by an attorney of their own choosing.

c . Advise the part ies that each has a r ight to be represented at

the c losing by an attorney i f they desire.

d. In sp i te of the permission to prepare such documents, there wi l l

inevi tably ar ise s i tuat ions in which the legal compl icat ions are

beyond the knowledge of the broker. In such instances an

attorney ’s assistance should always be sought.

In conclusion, i t could be said that the Supreme Court wi l l a l low the

brokers to prepare these legal documents on standard and approved

pr inted forms by f i l l ing in the b lanks there in, wi th in formation obta ined

from the usual sources, in transact ions wi th which they are connected

as brokers, when they receive no compensat ion for these acts other

than their ord inary commission. I t is to the interest of every broker that

these l imi ta t ions be proper ly recognized and fo l lowed so that the

Supreme Court would not have a reason to change i ts opin ion at a

future date.

The f ina l words of Mr. Gorsuch ’s summary bear repeat ing: “ I t is to the in terest

of every broker that these l imi tat ions be properly recognized and fo l lowed so that

the Supreme Court would not have a reason to change i ts op in ion at a

future date.”


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With pr iv i lege granted, there must be no abuse. The same author i ty that

granted it may take a pr iv i lege such as this away. A pr iv i lege respected may be

reta ined. A careless regard is not suff ic ient. There must be a carefu l

determinat ion and appl icat ion of what is author ized pract ice of law by a real

estate broker.

The court in its decis ion referred to the use of “standard and approved ”

forms, but did not e laborate. Consequently, i t was necessary to establ ish what

is a STANDARD and what is an APPROVED form.

Any form purchased from a stat ionery store or a pr inter may or may not be a

“standard and approved ” form. The pr in ter is under no obl igat ion to determine

what is standard or what is approved. However, a real estate broker may have

such an obl iga t ion . Therefore, the brokers needed some guidance and support in

their determinat ion of what is a standard and approved form.

In the years fo l l owing the Conway-Bogue dec is ion, the bus iness o f real es ta te

prac t ice grew rapid ly . There appeared to be less and less standardizat ion of

legal forms. Each associat ion of brokers, each local i ty , and even indiv idual

brokers used their own forms, of ten t imes drafted wi th

personal prejudice.

The real estate industry became concerned that i ts pr iv i lege to pract ice law,

wi th in the l imi ted sphere, might be abrogated by the court . In 1970, the Colorado

Associat ion of Real Estate Boards passed a resolut ion request ing the Real Estate

Commission to approve standard forms and to make their use compulsory. In

response to this request, the Real Esta te Commission held publ ic hear ings on

the quest ion. The consensus of opinion drawn from the hear ings was a lmost

unanimous: the industry wanted the Commission to use its author i ty to

standardize forms throughout the state. As a resul t , the Commission in 1971

promulgated and adopted Rule F, which was submitted to the Attorney

General . The Attorney General concluded that Rule F was a const i tu t ional

exercise of the Commission ’s ru le-making authority.


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Rule F covers forms for l is t ing contracts, sa les contracts, exchange contracts,

d isc losure forms, sett lement sheets, ex tension agreements, and

counterproposals. At the t ime of this wr i t ing, Rule F does not cover forms for

business opportuni ty l is t ing or sales contracts, management agreements, leases,

warranty deeds, etc. In these areas, the broker must use his or her

best judgment.

In 1993, the leg is lature gave the Commission statutory author i ty to

promulgate standard forms for use by real estate l icensees.

(See § 12-61-803(4), C.R.S.)

In the area of l ist ing and conveyancing covered by Rule F, it is to the

advantage of the general public and of real estate l icensees to use the

Commission-approved forms. Much of the wording used in these approved forms

has been interpreted by the Colorado Supreme Court and its meaning is known.

Other port ions have been rewri t ten to conform to Colorado Supreme Court

opin ion when o lder provis ions have been found inval id . Economic condi t ions have

also necessi tated changes. Changes can a lso be expected in the Commission-

approved forms, but reasonable not ice wi l l a lways be g iven to l icensed brokers.

Compan ion Dec is ion on Pra c t i c e o f Law

On the same day as Conway-Bogue, the Colorado Supreme Court decided the

cases of T i t le Guaranty Co. v. Denver Bar Assoc iat ion and Record Abs t ract & Ti t le

Co. v . Denver Bar Associat ion, which were taken as companion cases from which

one decis ion was rendered (see 312 P.2d 1011 (Colo. 1957)).

In these two cases, the Denver Bar Associat ion sought to enjo in the t it le

company and the abstract company from prepar ing certa in legal documents for

others, g iv ing advice as to their legal e ffect , and performing other acts that

a l legedly const i tu ted the unauthor ized pract ice of law.

The court reduced the issues to three:

1. Wherein one of the defendant corporat ions prepared papers incidenta l to

the making of a loan from funds belonging to the corporat ion.


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The court held that in such a case, the defendant may prepare the notes, deeds

of trust, or mortgages incidenta l to making the loans. The defendant could not be

restra ined even if at the t ime of the c losing the defendant had a f i rm commitment

for the sale of the loan.

2. In s i tuat ions where the part ies involved in the transact ion used an

“escrow service ” or “closing serv ice ” provided by the defendant

corporat ions wherein they draft deeds, promissory notes, trus t deeds,

mortgages, and receipt and opt ion contracts , and the defendants set a

min imum fee and a s l id ing scale of charges for th is service.

The court mentioned that the defendants act ive ly sol ic i ted such business,

a l though it was the same service that real estate brokers rendered as an

incident of their business and without separate charge. The court held that

the defendants were conduct ing a separate, d ist inct ,

and other business, much of which const i tu ted the pract ice of law and could

proper ly be restrained.

3. The th i rd problem presented was where the defendant ’s “closing

serv ice ” was used and the defendant also sold t it le insurance on the

property involved.

The court held that the defendants could be enjo ined and that the “escrow

service ” or “closing serv ice ” was not necessary or incidenta l to the issuance of

t i t le insurance. The court fur ther held that the attorneys employed by them were

represent ing the corporat ion and not the part ies involved. The court sa id in part ,

“To hold otherwise would be to author ize corporat ions to pract ice law

for compensat ion.”

The court began i ts opin ion by stat ing that i t should be read and considered in

connect ion wi th the opin ion on the case between the real estate brokers and

the lawyers.


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I I . L i ce n se e Ac t i ng o n Own Accoun t—C om miss ion Ju r i sd i c t ion

The Commission staff is of ten asked whether i t can invest igate compla ints

against a l icensee where the l icensee is not involved as an agent in the

transact ion. The answer is yes. The Commission can invest igate and take

d iscip l inary act ion against a l icensee act ing on the l icensee ’s own account where

the l icensee acts in a d ishonest manner. Typical examples are where the

l icensee/owner does not d isclose a known defect, fai ls to d isclose the l icensee ’s

l icensed status as a purchaser, or provides fraudulent in formation on a

loan appl icat ion.

Pr inted in re levant part below is the Colorado Court of Appeals case of Seibel

v. Colorado Real Estate Commiss ion, 530 P.2d 1290 (Colo. App. 1974) in which the

issue of the Commission ’s jur isd ict ion over “non-agency ” act iv i t ies arose.

Ed. Note: The s tatutes c i ted in th is opin ion are now found in

§§ 12-61-101 through -811, C.R.S.

This appeal ra ises the quest ion of jur isd ict ion of the Colorado Real

Estate Commission over acts of a broker in negot iat ing the acquisi t ion

of an interest in real estate for his own use. The hear ing off icer and

the Colorado Real Estate Commission, d i rect ly , and the d istr ic t court ,

by impl icat ion, a l l concluded that the real estate brokers l icensing act,

C.R.S. 1963, 117-1-1 , et seq. , and rules adopted by the commission

pursuant to that statute do apply to the conduct of l icensed brokers in

real estate matters re lat ing to act ions taken for their own account.

We aff irm.

Appel lant (Seibel) is a l icensed real estate broker. Intending to

purchase a home owned by persons named Debord for his own use,

he signed a receipt and opt ion agreement, proceeding through the

l is t ing broker, Roberts. Seibel was not able to c lose on the agreed

date, and accepted return of h is deposit .

Several days later, one Arvidson signed a receipt and opt ion

agreement re lat ing to the same property, again proceeding through


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Roberts. Seibel was not aware of this transact ion. He personal ly

contacted the Debords and at tempted to have them sign a new contract

for sa le of the property to h im. This proposed contract sta ted that

Seibel and Roberts would divide the commission equal ly . Al l of the

contacts by Seibel with the Debords regarding the second contract

were made wi thout the consent or approval of the l is t ing broker.

After Seibel learned of the Arvidson contract, he recorded the

or ig inal receipt and opt ion agreement. The Debord- Arvidson sale was

c losed wi th $500 being p laced in escrow to cover the cost of a possib le

quiet t i t le su i t to c lear the records of the Seibel contract.

Pursuant to statute, proceedings were held before a hear ing off icer

of the Colorado Real Estate Commission on al leged v io lat ions of both

the real estate brokers l icensing act and a commission ru le. The hear ing

off icer found that the commission had jur isd ict ion, that Seibel was

gui l ty of improper and dishonest deal ing in making d i rect contact wi th

the sel lers, that Seibel had vio lated both C.R.S. 1963, 117-1-12(1)( t) ,

and Real Estate Commission Rule E-13, and therefore recommended

that his l icense be suspended for a per iod of not less than th i r ty nor

more than ninety days.

C.R.S. 1963, 117- l -12(1)( t) , proscr ibes conduct “which const i tu tes

d ishonest deal ing.” Real Estate Commission Rule E-13 speci f ies that:

“A real estate broker shal l not negot iate a sale, exchange, lease or

l is t ing contract of real property d i rect ly wi th an owner for compensat ion

from such owner if he knows that such owner has a wr i t ten unexpired

contract in connect ion wi th such property which grants an exclusive

r ight to sel l to another broker, or which grants an exclusive agency to

another broker.

The Real Estate Commission approved and adopted the f indings of

the hear ing off icer, and suspended Seibel ’s l icense for a per iod of

th i r ty days. The distr ic t court reversed the commission ’s f ind ing that

Seibel had vio lated the statute, but af f i rmed the f ind ing that he had


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vio lated Rule E-13. The matter was remanded to the commission to

impose whatever penal ty the commission fe l t was warranted for the

vio lat ion of the ru le. The commission thereupon suspended p la int i f f ’s

l icense for ten days, and th is appeal fol lowed.

Seibel urges that 1965 Perm. Supp., C.R.S. 1963, 117-1-2(4),

provides h im a speci f ic exemption from the author i ty o f the commission

in th is case, s ince he was attempting to buy the home for h is personal

use and was not act ing as a real estate broker. The pert inent

paragraphs of th is sect ion state that :

“(a) The terms ‘ real estate broker ’ or ‘ real estate salesman, ’ as

used in this art ic le , shal l not apply to any of the following:

….

(e) Any owner of real estate act ing personal ly, or a corporat ion

act ing through its of f icers, or regular salaried employees, in his

or its own behal f wi th respect to property owned or leased by him

or it , except as provided in subsect ion (2) of th is sect ion;

(f ) Any person, f i rm, partnership, associat ion act ing personal ly , or a

corporat ion act ing through its off icers or regular salar ied

employees, in his or i ts own behal f as pr incipa l in acquir ing or in

negot iat ing to acquire any in terest in real estate … .”

…

Consider ing the statute in l ight of these pr incip les, we conclude that the

purpose of the exemption sect ion of 1965 Perm. Supp., C.R.S. 1963, 117-

1-2(4), is to permit an owner of property to sel l i t , or to permit one to

purchase property for h is own account wi thout having to procure a real

estate l icense. These paragraphs have no appl icat ion to the matter of

d iscip l ine of l icensed real estate brokers and salesmen. To interpret the

statute as Seibel urges, would be to adopt an i l log ical and unduly

restr ic t ive meaning of the regulatory provis ions of the ent i re statute.


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…

Hence, we conclude that where a real estate broker is deal ing in real

estate for h is own account, the Colorado Real Estate Commission has

jur isd ict ion over his acts and can suspend or revoke his l icense for

proven v io la t ions of the l icensing statute or of the commission ’s ru les.

A broker can no more be a l lowed to v io late the ru les of the Real Estate

Commission when purchasing property for h is own account than he can

when purchasing i t for a cl ient.

I I I . A t t o rn e y G en er a l ’s Op in io n on Bu s in es s Oppor tun i t i es

Michael B. Gorham,

Deputy Director Div is ion of Real Estate

Dear Mr. Gorham:

I am responding to your request of February 9, 1983, for an attorney

general ’s opin ion concerning the requirement of a real estate l icense to

receive a commission in the sale of a business opportuni ty and possib le

except ions to that requirement.

QUEST IONS PRESENTED AND CONCLUSIONS

Your quest ions ask

1. A person receives compensat ion for performing acts as basical ly set for th

in C.R.S. 1973, 12-61-101(2)( i ) . Does the statute require such a person to

obta in a real estate broker ’s l icense where the change in ownership or

in terest in real estate is an integral part of the business or business

opportuni ty transact ion, but is not negot iated or offered by the person? The

answer to your f i rs t quest ion is “yes ” , unless the person fa l ls wi th in one of

the statutory exemptions conta ined in C.R.S. 1973, 12-61-101(4), as

amended, or C.R.S. 1973, 12-61-101(2)( i ) .


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2. I f the answer to No. 1, is “yes” under what c i rcumstances, i f any, could a

person involve h imsel f in the transfer of a business or business opportuni ty

for compensat ion wi thout v io lat ing C.R.S. 1973, 12-61-101(2)( i) .

The statute under considerat ion, C.R.S. 1973, 12-61-101(2)( i ) , grants an

except ion to the requirement of a real estate l icense to receive a commission

for the sale of a business opportuni ty. Other c i rcumstances where a l icense

is not required are those s i tuat ions with in the ambit of C.R.S. 1973,

12-61-101(4), et seq.

ANALYSIS

C.R.S. 1973, 12-61-101(2)( i ) , as amended, sets for th a def in i t ion of a “ real

estate broker ” in the sale of a business opportuni ty . The s tatute states:

(2) “Real estate broker ” or “broker ” means any person, f i rm, partnership,

associat ion, or corporat ion who, in considerat ion of compensat ion by fee,

commissions, sa lary, or anyth ing of value or with the intent ion of

receiv ing or col lect ing such compensat ion, engages in or offers or

attempts to engage in, either d i rect ly or indirect ly , by a cont inuing course

of conduct or by any s ingle act or transact ion, any of the fo l lowing acts:

( I) Negotiat ing or attempt ing or offer ing to negot ia te the l is t ing, sa le,

purchase, exchange or lease of a business or business opportuni ty or

the goodwi l l thereof or any in terest there in when such act or

transact ion involves d irect ly or indirect ly any change in the ownership

or in terest in real estate, or in leasehold interest or estate, or in a

business or business opportuni ty which owns an interest in real estate

or in a leasehold unless such act is performed by any broker-dealer or

insurer-dealer l icensed under the provis ions of ar t ic le 51 of t i t le 11,

C.R.S. 1973, who is actual ly engaged general ly in the business of

offer ing, se l l ing, purchasing or trading in secur i t ies or

any off icer, partner, sa lesman, employee or other author ized

representat ive or agent thereof ;


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C.R.S. § 12-61-101(2) ( i ) was adopted in 1965 in response to the Colorado

Supreme Court ’s dec is ion in Cary v. Borden Co., 153 Colo. 344, 386 P.2d 585

(1963). In that case, the Supreme Court , based on the o ld def in i t ion of a real

estate broker found in C.R.S. § 117-1-2(1), adopted the minor i ty New York ru le

and a l lowed recovery of a commission by an unl icensed person in the

sale of a business opportuni ty where the in terest in real estate was not the

dominant feature of the whole transact ion.

In Broughal l v . Black Forest Development Co., 196 Colo. 503, 593 P.2d 314

(1978), the Colorado Supreme Court found that the legis lat ive in tent of C.R.S. §

12-61-101(2)( i ) in changing the def in i t ion of a real estate broker was to br ing

Colorado in l ine wi th the major i ty New Jersey ru le. That rule def ines a real

estate broker to include anyone who negotiates any transact ion that d i rect ly or

indirect ly involves a change in ownership in real estate or who negotiates a

change in ownership of a business or business opportuni ty which includes an

interest in real estate or in a leasehold . Kenny v . Pat te rson Mi lk & Cream Co. , Inc. ,

110 N.J .L . 141, 164 A. 274 (1932). This def in i t ion does not require that the

change in the interest in real esta te or in a leasehold be negot iated. Nor does

the def in i t ion require that the change in ownership or in terest in real estate be

an integral part of the transact ion. Furthermore, the transact ion is not severable

so that an unl icensed person may receive a commission on the port ion of the

sale not involv ing real estate, i f the transfer as a whole involves the transfer of

an in terest in land or a leasehold. Broughal l v . B lack Fores t Development

Co. , supra.

C.R.S. 1973, 12-61-101(2)( i ) does not require that the transfer of an interest

in real estate or a leasehold be negot iated or offered to br ing one wi th in the

def in i t ion of a real estate broker. I t only requires that one negot iate a transfer of

a business or business opportuni ty, and that the business or business opportuni ty

include an interest in real estate or a leasehold.

Furthermore, the statu te in quest ion sets for th a very broad def in i t ion of

“negotiat ing ” . “Negotiat ing ” has been in terpreted to mean the simple act of

in troducing the buyer and sel ler , thus br inging that act under the l icense laws

and requir ing a l icense before receiv ing a commission on the sale of a bus iness

http://advance.lexis.com/api/document/citation/110%20N.J.L.%20141




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oppor tuni ty . B rakhage v . Georgetown Assoc ia tes ,

33 Colo . App. 385, 523 P.2d 145 (1974).

Because the answer to quest ion 1 is “yes” I wi l l set for th the c i rcumstances

under which a person could receive compensat ion for the sa le of a business

opportuni ty, a l though not l icensed as a real estate broker.

[The Opin ion sets for th a l l o f the except ions to l icensing requirements under

12-61-101(4). These are not repeated for the sake of brevity.]

Therefore, i f a person fa l ls wi th in one of these except ions, he does not need to

obta in a real estate broker ’s l icense.

Summa ry

The change in the l icensing law to br ing Colorado under the major i ty New

Jersey ru le requires that a person must be l icensed to receive compensat ion for

the sale of a business or business opportuni ty where there is also a transfer of

an interest in real estate or a leasehold, no matter whether the interest or

leasehold is negot iated or if the interest is insigni f icant in comparison to

the rest of the transact ion. Also, the transact ion must not be separable so that one

can avoid the l icensing requirement and col lect compensat ion on the basis of the

sale of the business or business opportuni ty only.

Circumstances under which persons may receive compensat ion without a

l icense are set for th in the except ion provided in §12-61-101(2)( i ), C.R.S. and the

except ion to the def in i t ions of “ real estate broker ” found in § 12-61-101(4), C.R.S.

Ed. Note: The l icense law statutes c i ted in th is opin ion are now

found in § 12-61-101(2), C.R.S.

(DORA, 6-1 – 6-9)

Ci ted Mater ia l:

DORA. "Chapter 6 : Landmark Case Law and Opin ions ." Colorado Real Estate

Manual . Char lot tesvi l le, VA: Lex isNexis, 2014. . Pr int.

http://advance.lexis.com/api/document/citation/COLO.%20REV.%20STAT.%2012-61-101

http://advance.lexis.com/api/document/citation/COLO.%20REV.%20STAT.%2012-61-101

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