Price v. Sommermeyer
In Price v. Sommermeyer, 195 Colo. 285, 577 P.2d 752 (1978) the Court held that a decedent's potential right of indemnity under a liability insurance policy constituted personal property for purposes of the Colorado Probate Code.
The court noted that it would be "indulging in nothing less than strained and artificial refinement were we to now hold that this same contractual obligation does not qualify as property of the insured for the purpose of a court's assertion of quasi in rem jurisdiction." Baker v. Young.
Thus, it determined that neither the intangible character nor the contingent nature of the right under the policy should logically prevent it from being the subject of ownership.