A Colorado appeals court reversed a lower court’s ruling that had been based on an insurer’s internal settlement evaluation, after determining that such an evaluation doesn’t establish an ”undisputed” amount of benefits owed.

In a March 30 opinion, the Colorado Court of Appeals reversed and remanded a trial court’s ruling after concluding it had erred in relying on defendant Geico Casualty Co.’s internal settlement evaluation as a basis for concluding that some portion of plaintiff Marcus A. Fear’s claimed noneconomic damages were “undisputed.”