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LeaseDecoded Research Team
Statutes verified against primary state sources
How this page is sourced
Every statute cited here was checked against the state's own published text before this page went live. Court decisions are quoted from the published opinion and linked to it, so you can read the original yourself.
Primary sourcesNot legal advice
Content verified against primary state statutes before publication Last updated: September 2026

Quick Summary - What You Need to Know

  • Colorado has no statute forcing a landlord to re-rent after a lease break, so check current Colorado statutes and case law.
  • Colorado courts apply general contract mitigation principles, so a property manager who does nothing risks a reduced damages award.
  • C.R.S. § 38-12-801 separately voids some lease terms, including penalties tied to an eviction notice and one-way attorney-fee clauses.
  • Denver adds nothing on acceleration or mitigation, so state law and Colorado court decisions control from Baker to Green Valley Ranch.
  • Texas and New York void any waiver of the mitigation duty by statute; Colorado gives you no section number to point at.

Understanding the Lease Acceleration Clause

No statute; case law
Landlord duty to mitigate after an early lease break in De
Probably not in full - Colorado has no statute forcing your landlord to re-rent, so mitigation gets argued in court, not cited from a section number.

A lease acceleration clause says that if you leave early, every remaining month of rent comes due all at once. On a Denver two-bedroom with seven months left, that paragraph turns a move into a five-figure demand letter.

Colorado is one of the quieter states on this. There's no residential duty-to-mitigate statute in the landlord-tenant code, so whether your landlord had to try re-renting is a case-law and contract question rather than a line you can highlight.

What renters assume

Renters read the acceleration paragraph, assume the whole balance is legally owed the day they hand back keys, and pay it rather than fight.

What is actually true

A clause is a claim, not a judgment. Colorado courts apply general contract mitigation principles, so a landlord who does nothing to re-rent risks a reduced damages award.

Colorado is the blank space on this chart. Washington, Illinois, Arizona, and New York all wrote the duty into statute; Florida wrote the opposite; Colorado wrote neither, which means outcomes here vary more than almost anywhere else on the list.

Plain English Version

Think of it like walking out on a gym contract: the club still wants every remaining month. In most states a law forces them to try filling your spot, but in Colorado that pressure comes from a judge weighing what was reasonable, not from a rulebook you can point to.

Clause decoder

Rent Acceleration Clause Example - What the Wording Looks Like in Denver, CO

The sample clause below is real lease language - a court quoted it word for word, and then ruled on it. What the judge decided is at the bottom of this block.

Real clause - quoted in a published court opinion

Find the equivalent paragraph in your own lease and read the two side by side. The wording will differ; the moving parts rarely do.

The acceleration paragraph from the opinion. Read it as a partial paragraph: one more sentence, about late fees and interest on accelerated amounts, follows in the original and is not printed here:

If any monthly installment under this agreement is not paid when due and remains unpaid after a date specified by a notice to Tenant, the entire principal rent amount owed for the full lease term shall at once become due and payable at the option of the Landlord and judgment may be had for all said amounts due. The foregoing provision shall not relieve the Landlord of its obligation to mitigate damages. In the event the rental premises is re-rented to another for full value prior to expiration of the lease term, Landlord shall file Notice of Partial Satisfaction of any judgment entered to the extent of the third party rental agreement.

[…]

Quoted from the published opinion in Summers v. Crestview Apartments, 2010 MT 164, 357 Mont. 123, 236 P.3d 586 (No. DA 09-0489). Judicial opinions are not subject to copyright; the lease language is reproduced in limited part for commentary under 17 U.S.C. § 107.

1

“under this agreement”

In Colorado the agreement carries more weight than it does in the states on this page that write the duty into their code. Texas and New York both do, and both void a lease term that waives it, so there the statute settles the question before the lease is opened. Our Colorado record identifies no such statute for residential tenancies. That leaves the paragraph you signed as the first document anyone reads, with general contract mitigation principles from Colorado's courts shaping it from outside - and check the current statutes before relying on it.

Tenant-favourable“The terms of this Agreement are subject to all rights Tenant has under Colorado law”
What this lease said“under this agreement”
Landlord-favourable“This Agreement is the entire understanding and no rule outside it shall limit Landlord’s remedies”
2

“The foregoing provision”

In Texas or New York this sentence is surplus, because the duty it concedes is statutory and cannot be waived there. In Colorado it is worth more, because it is a promise inside your contract rather than a restatement of a code section - and our Colorado record locates the mitigation rule in general contract principles and case law rather than in the landlord-tenant statutes. A lease that contains this sentence and a lease that omits it are not obviously in the same position here.

Tenant-favourable“Landlord’s duty to mitigate is an independent obligation and survives any default by Tenant”
What this lease said“The foregoing provision”
Landlord-favourable“The mitigation reference in this paragraph is precatory and creates no obligation enforceable by Tenant”
3

“for full value”

Nothing in the lease obliges the landlord to accept less than the old rent, and no Colorado statute in our record supplies that obligation. What our Colorado record does supply is the consequence of inaction: Colorado courts apply general contract mitigation principles, so a landlord who does nothing at all risks a reduced damages award. The argument is available. It is simply built out of case law rather than out of a section number you can point at.

Because the rule is judge-made, the facts do more work here than any citation does. Dates, listings, asking rents and the day a new tenant moved in are what a Colorado court would be looking at.
Tenant-favourable“Landlord shall offer the premises at a rent no higher than the market rate then prevailing”
What this lease said“for full value”
Landlord-favourable“Landlord shall have no obligation to relet at any rent below the rent reserved in this Lease”
4

“of any judgment entered”

Judgments are where Colorado does have a statute pointed at lease terms. C.R.S. § 38-12-801 voids several kinds of clause outright, including penalties tied to an eviction notice or an eviction action and one-way attorney-fee clauses - the terms that make the process itself expensive. Our Colorado record for that section is about those voided terms and does not reach the mitigation question, which is why the rest of this page rests on case law - but it is the provision to read next to anything in your lease that adds a charge because a filing happened.

Tenant-favourable“No fee, penalty or charge shall arise from the service of a notice or the filing of an action”
What this lease said“of any judgment entered”
Landlord-favourable“Tenant shall pay a $250 administrative charge on service of any notice, plus Landlord’s fees in any action”
What the court did with it

The Montana Supreme Court struck this paragraph down, and its conclusion is one sentence: “Thus, we conclude that the accelerated rent provision is unconscionable and therefore unenforceable.” The tenants had moved out of their apartment on October 13, 2006, and Crestview answered with a Statement of Deductions from the Security Deposit charging rent through the end of the lease in June - $6,505.75 billed against a $2,170 deposit. Two reasons carried the court. Acceleration undermines the landlord's duty to mitigate and reduces the incentive to re-rent promptly, because a landlord already holding a judgment for the whole term has little reason to fill the unit. And Crestview drafted the lease while these tenants had no meaningful choice and no opportunity to negotiate any of it. The case was reversed and remanded, and two justices wrote separately - their objection being that the majority had gone as far as treating acceleration clauses as unenforceable in themselves. So read the holding narrowly, as the majority wrote it: this provision, in this residential lease, unconscionable and unenforceable. It is a Montana decision and it binds no other state's courts. What travels is the reasoning, and the reasoning is about mitigation - which is exactly the question the statute in your own city's decode answers.

In Colorado the answer does not come out of the landlord-tenant statutes at all. Our Colorado record finds no statute imposing an express duty to mitigate on a residential landlord after a tenant breaks a lease. What applies instead are general contract mitigation principles from the courts, so a landlord who does nothing risks a reduced damages award, and because the rule is judge-made rather than statutory the outcomes vary more than in states with an express mitigation statute. Our Colorado record carries no statutory citation on this question, so read the current statutes and recent Colorado decisions for yourself rather than treating any of this as settled. The record's citation is:

One court, one lease, one state. That answer is not automatically yours, and your lease may be worded to land differently. Use this to know what to look for and what to ask - your state's tenant hotline or a local tenant attorney can answer it for your document.

Colorado Law on Lease Acceleration Clause

The law in Colorado
  • No Colorado statute imposes an express duty to mitigate on a residential landlord after a tenant breaks a lease.
  • Colorado courts apply general contract mitigation principles, so a landlord who does nothing risks a reduced damages award.
  • C.R.S. § 38-12-801 separately voids several lease terms, including penalties tied to an eviction notice or action and one-way attorney-fee clauses.
  • Because the rule is judge-made rather than statutory, outcomes vary more than in states with an express mitigation statute.

Verify the current text in your state's landlord-tenant statutes.

Start with what isn't there. No Colorado statute imposes an express duty to mitigate on a residential landlord after a tenant breaks a lease, so the protection you have comes from judges applying ordinary contract principles instead of a statutory cap.

That difference is real. In Texas, a lease clause waiving mitigation is void under Tex. Prop. Code § 91.006, and New York's RPL § 227-e does the same; in Colorado you argue that the landlord's damages shrank because a reasonable owner would have re-rented. Colorado does void certain lease terms under C.R.S. § 38-12-801, including penalties tied to an eviction notice or action, so read the fine print and confirm the current statutes before you rely on any of it.

Colorado Tenant Protections

Colorado courts apply general contract mitigation principles, so a landlord who sits on an empty unit and does nothing risks having the damages award cut down. C.R.S. Section 38-12-801 voids several lease terms outright, including penalties tied to an eviction notice or action and one-way attorney-fee clauses. An acceleration clause does not collect itself, so a landlord who wants that money has to sue and convince a Colorado judge, which is exactly where the mitigation argument lives.

What's Specific to Denver

Landlord duty to mitigate after an early lease break

Same clause, 16 cities, different rules. Tap any city for its own guide.

Austin, Texas
Mandatory, non-waivable
Los Angeles, California
Mandatory, tenant proves
New York City, New York
Mandatory, non-waivable
Miami, Florida
No duty to re-rent
Chicago, Illinois
Mandatory statewide
Seattle, Washington
Mandatory on abandonment
Denver, Colorado
No statute; case law
Phoenix, Arizona
Mandatory after abandonment
Atlanta, Georgia
Likely no duty
Nashville, Tennessee
Mandatory in large counties
Philadelphia, Pennsylvania
No duty to re-rent
Portland, Oregon
Mandatory on abandonment
Boston, Massachusetts
No statute; 93A limits
Las Vegas, Nevada
Mandatory on abandonment
Washington, District of Columbia
Mandatory, actual damages
Columbus, Ohio
No statute; case law

Figures are the state rule, or the stronger city ordinance where one exists. Verify the current law for your own situation before relying on it.

Denver adds nothing here. There's no city ordinance on rent acceleration or mitigation, so the same rules apply whether you're leaving a Cap Hill walk-up or a new build in RiNo, and state law plus Colorado case law is the whole story.

Local market reality does the heavy lifting instead. Denver absorbed a large wave of new apartments, and buildings offering a free month or waived fees re-rent quickly, which shrinks the shortfall a property manager can actually prove, so screenshot your old unit's new listing the day it reappears.

Does the lease say how damages get calculated?

A fair one shows the math and credits rent from a new tenant. Colorado sets no formula, so the lease language carries more weight here.

Does it promise reasonable efforts to re-rent?

Good sign. Written re-rental language gives you a contract term to enforce, since Colorado has no statute creating that duty for you.

Does it demand all remaining rent immediately?

Red flag. Acceleration on day one ignores mitigation entirely, and Colorado judges weigh what a reasonable owner would have done to re-rent.

Does it make you pay the landlord's attorney fees?

Push back. C.R.S. § 38-12-801 voids one-way attorney-fee clauses, so that paragraph may not survive a challenge.

Red Flags to Watch Out For

  • All remaining rent due at once

    The clause bills every unexpired month the day you hand over keys. Colorado has no statutory cap on that demand, so the mitigation argument has to be made, not cited.

  • No duty to re-rent language

    Wording saying the owner need not look for a new tenant. Texas and New York void that waiver outright; in Colorado you're left arguing contract law.

  • Acceleration stacked on re-letting fees

    The lease takes all remaining rent and a separate lease-break or re-letting charge. Ask in writing which amounts are credited against the other before paying.

  • Charges tied to an eviction notice

    A fee that fires the moment a notice gets posted on your door. C.R.S. § 38-12-801 voids penalties tied to an eviction notice or action.

  • Deposit kept plus accelerated rent

    Your full deposit is forfeited and the balance still arrives. Demand a written itemization showing exactly what was credited against what.

Your Rights as a Denver Tenant

  • Mitigation still gets argued

    Colorado courts apply general contract mitigation principles, so a landlord who does nothing to re-rent risks a reduced damages award in court.

  • Some lease terms are void

    C.R.S. § 38-12-801 voids several lease provisions, including penalties tied to an eviction notice or action and one-way attorney-fee clauses.

  • Proof, not a printed number

    An acceleration clause is a claim. Ask for the re-rental date, the new rent, and receipts before you treat the balance on that statement as owed.

  • Evidence you can gather yourself

    The new listing for your old unit is your best exhibit. Screenshot the date and price the moment it reappears on Zillow or Apartments.com.

What To Do - Step by Step

1

Find the acceleration paragraph

Search your lease for 'accelerate', 'all remaining rent', or 'balance of the term'. Copy the exact wording, because that's the number your landlord will start from.

2

Give dated written notice

Email it and mail it. Colorado has no statute fixing when the clock starts, so a provable move-out date is your own protection.

3

Photograph everything, return keys

Document condition room by room and hand back keys on a date you can prove. Rent and damage disputes get settled from the same paper trail.

4

Track the relisting weekly

Check Zillow, Apartments.com, and the building's own site. A unit relisted within days is evidence the real shortfall is far smaller than the demand.

5

Demand an itemized statement

Ask in writing for the re-rental date, the new rent, and receipts for actual costs. Don't pay a lump sum with no math behind it.

6

Get Colorado tenant help

Call Colorado Legal Services or the Colorado Poverty Law Project before signing a repayment plan. Because the rule here is judge-made, early advice matters more.

Frequently Asked Questions

can my landlord make me pay the rest of my lease in denver
They can demand it, but collecting is another matter. Colorado has no statute capping the demand, though courts apply general contract mitigation principles, so a landlord who never tried to re-rent risks a reduced award.
does my landlord have to re-rent my apartment in colorado
There's no Colorado statute saying so. The duty comes from case law and general contract principles instead, which is why outcomes vary more here than in Washington or Illinois, where mitigation is written into the code.
is a lease acceleration clause legal in colorado
Generally yes, Colorado doesn't ban them. What it collects is the real question, since mitigation gets weighed by a judge. C.R.S. § 38-12-801 separately voids certain lease terms, so check the current statutes.
what happens if i just move out early in denver
Expect a demand for the remaining rent, plus fees. Denver adds nothing to the state rules, so document your move-out, watch for the relisting, and get advice before paying a lump sum.
what is the landlord duty to mitigate after an early lease break in denver
Colorado: No statute; case law. Colorado has no residential duty-to-mitigate statute; any mitigation requirement comes from case law and general contract principles rather than the landlord-tenant code.
does denver add its own rule or does colorado law decide
Denver adds nothing on rent acceleration or mitigation; state law and Colorado case law control.
how does colorado compare with other states on this
Colorado: No statute; case law. Texas: Mandatory, non-waivable. The chart above on this page shows every city side by side.
what else does colorado law say about this
No Colorado statute imposes an express duty to mitigate on a residential landlord after a tenant breaks a lease.
Legal Disclaimer: This guide is for general educational purposes only and does not constitute legal advice. Information reflects general Colorado and Denver law as of September 2026 but may not reflect recent changes. Consult a licensed attorney in Colorado for advice about your specific situation.