Because the term "ski season" is undefined in Passholders' and Vail's contracts, "we interpret it according to its plain meaning." Renfandt v. N.Y. Life Ins. Co., 419 P.3d 576, 580 (Colo. 2018). "When determining the plain and ordinary meaning of words, we may consider definitions in a recognized dictionary."

It has, however, recently noted the "longstanding public policy in Colorado that disfavors suicide exclusions." Renfandt v. New York Life Ins. Co. , 419 P.3d 576, 584 (Colo. 2018). It has also noted, in the context of differentiating between voluntary and "involuntary" (self-destruction without the intent to kill oneself) suicide, that § 10-7-109 was "capable of but one rational construction, namely, that it was the intent and purpose of the Legislature to prevent all companies, of whatsoever kind or character, issuing life insurance contracts, from escaping payment thereon, in the event of death, simply on the ground that the insured committed suicide."

"When determining the plain and ordinary meaning of words, we may consider definitions in a recognized dictionary." Renfandt v. N.Y. Life Ins. Co. , 2018 CO 49, ¶ 18, 419 P.3d 576, 580. 3. Providence is Inapposite

¶29 Section 10-7-109 "reflects a longstanding public policy in Colorado that disfavors suicide exclusions." Renfandt v. N.Y. Life Ins. Co. , 2018 CO 49, ¶ 44, 419 P.3d 576, 584. Thus, although the statute allows the assertion of suicide as a defense to payment on life insurance policies, it limits the right to assert that defense to the first year of the policy.

Effective July 1, 1995, our General Assembly "modified the test for insanity to fold in the former affirmative defense for ‘impaired mental condition.’ " Renfandt v. N.Y. Life Ins. Co. , 2018 CO 49, ¶ 48, 419 P.3d 576, 585. Thus, what used to be the defense of "impaired mental condition" is now subsumed within the defense of insanity.

We may consult definitions in recognized dictionaries to give undefined words their plain and generally accepted meaning. Renfandt v. N.Y. Life Ins. Co. , 2018 CO 49, ¶ 18, 419 P.3d 576, 580. ¶14 If the contract is complete and free from ambiguity, we deem it to represent the parties' intent and enforce it based on the plain and generally accepted meaning of the words used.

But the Colorado cases that Purchasers rely on for this proposition are about coverage disputes. See, e.g., Renfandt v. New York Life Ins. Co., 2018 CO 49, ¶¶ 17-18, 419 P.3d 576; GEICO Cas. Co. v. Collins, 2016 COA 30M, ¶¶ 18-19, 371 P.3d 729; Public Service Co. of Colorado v. Wallis & Companies, 986 P.2d 924, 931 (Colo. 1999). And both things can be true-i.e., courts can construe ambiguities regarding coverage in favor of the insured, while then construing any ambiguities about the applicability of an arbitration clause in a covered case in favor of arbitration.

In doing so, we "may consider definitions in a recognized dictionary." Renfandt v. N.Y. Life Ins. Co., 419 P.3d 576, 580 (Colo. 2018) (applying Colorado law). Such dictionaries include Black's Law Dictionary ("Black's"), the Oxford American Dictionary ("Oxford American"), and Merriam-Webster Online Dictionary ("Merriam-Webster").

And when a term in an insurance policy is undefined, we may look to dictionary definitions to discern its plain meaning. See Renfandt v. N.Y. Life Ins. Co., 419 P.3d 576, 580 (Colo. 2018). Perhaps anticipating this result, Krum next argues that this conclusion fails to give effect to the plain and ordinary meaning of the verb "rent."

Because the Policy does not define that phrase, we must look elsewhere to discern its plain meaning. See Renfandt v. N.Y. Life Ins. Co. , 419 P.3d 576, 580 (Colo. 2018). Dictionary definitions are a good place to start.