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Pinto v. United Services Automobile Ass’n.

2026 CO 44. No. 26SA29. Insurance—Evidence—Scope of Discovery.

June 8, 2026


The supreme court held that the trial court did not err in declining to extend Schultz v. GEICO Casualty Co., 2018 CO 87, 429 P.3d 844, to breach of contract claims. The  court further held that the trial court did not abuse its discretion in compelling the production of Pinto’s medical records and insurance documents, and in ordering Pinto to undergo an independent medical examination because these materials were relevant to establishing her claim for uninsured motorist benefits under her breach of contract claim.

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