Edward Kraemer & Sons, Inc. v. Downey
In Edward Kraemer & Sons, Inc. v. Downey, 852 P.2d 1286, 1288-89 (Colo. Ct. App. 1992), the court held that a carrier had to compensate a claimant for a spouse's assistance in eating, bathing, preparing him for bed at night and showering.
It also held that compensation was due for the spouse being available on an on-call basis in case her husband had an emergency even if she was also doing household work at the same time.
As the court reasoned, a third-party attendant being on-call would be entitled to payment even if he or she could do other activities and in either case the caregiver was passively providing attendant care. 852 P.2d at 1289.