CenturyLink, Inc. v. Houser.

2026 CO 20. No. 24SC644. Complaints—Sufficient Investigation—Copying of Allegations.

April 6, 2026

In this class action, shareholders filed a complaint alleging various securities law violations by a corporation. The supreme court granted certiorari to decide whether CRCP 11(a)’s duty to conduct an objectively reasonable inquiry is satisfied when an attorney copies information, including allegations by confidential witnesses, from complaints in related lawsuits involving some of the same defendants. The court concluded that counsel must conduct a sufficient investigation to support the allegations contained in a complaint, at least on information and belief. The extent of the investigation required, however, is highly fact-dependent, and thus a plaintiff’s copying of allegations contained in complaints in related actions does not alone violate counsel’s duty under CRCP 11(a) but rather must be considered in the context of each case. Applying those principles here, the court further concluded that plaintiff’s counsel conducted a sufficient investigation to allow counsel to include in the amended complaint in this case, consistent with counsel’s obligations under CRCP 11, allegations that were contained in complaints in related actions against some of the same defendants named here.

Accordingly, the court affirmed the judgment of the court of appeals division.