Colorado Joint Tenancy Rules

A will that gave property to two people "jointly and severally" sounded like it meant survivorship. A Colorado court disagreed, and one heir's share nearly went to the state instead.

Express language, no exceptions

Under C.R.S. § 38-31-101, no conveyance or devise of real property to two or more people creates a joint tenancy in Colorado unless the instrument expressly declares it — either that the property is conveyed or devised "in joint tenancy," or to the named people "as joint tenants." Without that declaration, ownership defaults to a tenancy in common, with no survivorship, and a co-owner's share goes through probate.

"Jointly and severally" wasn't enough

A real Colorado Supreme Court case shows how strictly this gets applied. A will left property to two people "jointly and severally" after paying debts and expenses. When one of the two beneficiaries died before the person who wrote the will, and that will-writer had no known heirs, the outcome hinged entirely on whether the devise created a joint tenancy or a tenancy in common — if it was a tenancy in common, the deceased beneficiary's share risked passing to the state instead of to his surviving co-beneficiary. A trial court had read the will as creating a joint tenancy, but the phrase "jointly and severally" doesn't expressly choose joint tenancy the way the statute requires, and Colorado courts have treated that kind of ambiguous language as insufficient on its own to create survivorship.

A 2008 law brought back the old test

Colorado's joint tenancy law itself has gone through a notable shift. For years, courts moved away from the traditional common-law "four unities" — time, title, interest, and possession — toward a looser standard based on the parties' actual intent, and Colorado's Supreme Court had suggested in dicta that the four unities doctrine had been abolished entirely by statute. The 2008 Colorado Joint Tenancy Act (House Bill 08-1248) responded directly to that: it amended § 38-31-101 to state that the four unities doctrine "is continued" as part of Colorado law, reinstating a more structured framework rather than relying purely on intent.

An owner can name themselves as a joint tenant

One modern flexibility survived that 2008 shift: any grantor in a conveyance can also be one of the named grantees. That means a sole owner of Colorado real estate can create a joint tenancy simply by conveying the property back to themselves and one or more other people as joint tenants, without needing to route the transaction through an intermediary "strawman" the way older common-law rules once required.

No extra wording needed once the core phrase appears

Colorado doesn't require a more elaborate phrase on top of the basic joint tenancy declaration. The abbreviation "JTWROS" and phrases like "as joint tenants with right of survivorship" or "in joint tenancy with right of survivorship" carry exactly the same legal meaning as the simpler "in joint tenancy" or "as joint tenants" — once the core declaration is there, survivorship is understood as part of it.

A newer tool, with its own quirks

Joint tenancy isn't the only way to keep Colorado real estate out of probate. See our guide to the Colorado beneficiary deed for a tool that works without a co-owner — and for why it interacts with an existing joint tenancy in a way that can surprise people.

Colorado joint tenancy — frequently asked questions

What does Colorado Revised Statute 38-31-101 require for a joint tenancy?

That the instrument conveying or devising the real property expressly declares it is conveyed or devised in joint tenancy, or to the named people as joint tenants. Without that express language, a conveyance to two or more people creates only a tenancy in common.

What happened in the Colorado case about "jointly and severally" language?

A will left property to two people "jointly and severally," without expressly choosing joint tenancy. The Colorado Supreme Court held this created a tenancy in common, not a joint tenancy, because the will did not clearly express an intent to create survivorship.

What did the 2008 Colorado Joint Tenancy Act change?

It amended Section 38-31-101 to provide that the common-law doctrine of the four unities of time, title, interest, and possession continues as part of Colorado law, reversing a trend in which courts had moved toward a looser test based purely on the parties' intent.

Can a Colorado property owner create a joint tenancy with themselves and others?

Yes. Any grantor in an instrument of conveyance may also be one of the grantees, so an owner of real property can create a joint tenancy by conveying the property back to themselves and one or more other people as joint tenants.

Do "JTWROS" and "with right of survivorship" mean anything different from "joint tenancy" in Colorado?

No. The abbreviation "JTWROS" and the phrases "as joint tenants with right of survivorship" or "in joint tenancy with right of survivorship" have the same legal meaning as simply "in joint tenancy" or "as joint tenants" under Colorado law.

This page provides general guidance only and is not legal advice. Figures and rules are based on Colorado statute (C.R.S. § 38-31-101) and published Colorado court decisions, verified per our methodology. Confirm how a specific deed or will is actually titled with the county Clerk and Recorder or a licensed Colorado attorney before acting.