Farmers Group, Inc. v. Trimble
In Farmers Group, Inc. v. Trimble, 658 P.2d 1370, 1378 (Colo. Ct. App. 1982), the court also found that no private right of action existed for first and third-party claims under the state's Unfair Claims Settlement Practices Act ("UCSPA").
The statute did not provide the right to a private civil action, but it did vest the Insurance Commissioner with broad discretion. Id.
The Commissioner could conduct investigations, order parties violating the act to cease and desist, issue monetary fines, and revoke licenses in addition to other powers. Id. at 1377.
Considering that the statute was extensive, the court reasoned that the legislature would have included a private right of action if it was their intent to allow private parties the right to sue under the statute. Id. at 1378.