Colorado Attorney General Phil Weiser announced a settlement Thursday with Cobblestone Denver Opco, LLC, resolving allegations that the car wash chain ran its monthly membership program in violation of the state’s automatic-renewal law. The number in the headline is $1,353,465. The number that actually matters to you is nineteen dollars.
That’s not a typo or an average. Read the assurance of discontinuance and paragraph 6.1 spells it out: every affected consumer receives a redress payment of $19, flat. Divide $1,353,465 by 19 and you get 71,235 people. It doesn’t matter whether you got quietly bumped $3 a month for two years or six months. Nineteen dollars.
Cobblestone denies the allegations and the document is explicit that it isn’t a finding that the company broke any law.
What the state says went wrong
Cobblestone runs more than 40 Colorado locations. The AG’s office says it opened the investigation in late 2024 after complaints about surprise price increases and cancellation hassles, then subpoenaed the company’s membership records that December.
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The alleged violations are specific, and they map onto individual subsections of C.R.S. § 6-1-732: changing the monthly price without notice, failing to disclose what happens when a trial period converts, failing to give customers a retainable written acknowledgment with the renewal terms and cancellation instructions, failing to warn members their contract would roll past twelve continuous months, and failing to provide a simple, timely, easy way out.
The scale: between August 2022 and February 2025, the state says more than 30,000 Coloradans got a rate increase with no notice, and over 40,000 never received a purchase receipt.
The eligibility rules are the real story
Here’s where it gets interesting, and where I’d point any car owner who’s ever bought an unlimited wash plan.
To qualify for your $19, you had to buy a membership between January 1, 2022 and February 2, 2025, not already have been refunded $19 or more, and then fit one of two buckets. Bucket one: you started at $25 a month or higher and experienced a price change. Bucket two: you didn’t get a receipt with the required auto-renewal terms — and you used the car wash four times or fewer.
That second criterion is doing something interesting. A customer paying monthly for unlimited washes who used four or fewer washes across a multi-year window isn’t a customer. That’s breakage — the industry term for revenue from people who pay and never show up. Unlimited-wash plans exist precisely because a meaningful chunk of subscribers wash far less than they think they will, and the tunnel’s marginal cost per wash is small enough that heavy users don’t sink the model. Breakage is the margin. When a regulator writes an eligibility test that specifically captures people who paid and barely used the service, it’s identifying the population most likely to have been enrolled without understanding the terms.
The timeline and the fine print worth knowing
The document was signed August 19, 2026. From that effective date, Cobblestone has 60 days to submit a redress plan and 150 days to mail every check and notice — putting payments in mailboxes by roughly mid-January 2027. There’s no claim form. A third-party administrator handles distribution, and the notice included with each check will point people to a claims line at 877-516-5377.
Three things that don’t usually make the coverage:
Cashing the check costs you nothing. Paragraph 6.7 bars Cobblestone from conditioning any payment on a consumer waiving any right. The assurance also disclaims creating any third-party rights, which cuts both ways — you can’t enforce the settlement personally, but the settlement doesn’t extinguish whatever private claim you might have.
Unclaimed money doesn’t stay with Cobblestone. Anything undeliverable after reasonable efforts reverts to the Attorney General, to be used at his discretion for restitution, future enforcement, consumer education, or public welfare. If your address has changed since 2022, that’s your $19 heading back to the state.
Complaining still works. For three years, the AG’s office has agreed to forward Cobblestone a copy of any consumer complaint about the company within 60 days. That’s an unusual provision, and it means a complaint filed through the state actually lands on the company’s desk.
One discrepancy worth flagging: the AG’s press release says Cobblestone already refunded $253,406 to more than 4,000 consumers during the investigation. Paragraph 6.9 of the signed document puts the same dollar figure at 2,204 Colorado consumers. The executed agreement is the controlling record.
Why a state AG is doing this instead of the FTC
Timing explains a lot. The FTC’s Negative Option Rule — the “click-to-cancel” rule — was days from taking full effect when the Eighth Circuit vacated it entirely in July 2025 on procedural grounds. That left the field to state automatic-renewal statutes, and Colorado’s, passed as HB21-1239, is one of the more prescriptive.
The company’s lawyers clearly saw the federal picture the same way. Paragraph 9.4 of the assurance says that if the Colorado legislature amends its law or the FTC promulgates a new negative-option rule, that rule supersedes the settlement’s injunctive terms wherever compliance with both would be infeasible. In other words, Cobblestone negotiated an off-ramp for whatever Washington does next.
The tax detail nobody mentions
Paragraph 6.1 doesn’t just say Cobblestone pays $1.35 million. It says the amount is not a fine or penalty and constitutes compensatory restitution within the meaning of 26 U.S.C. § 162(f)(2)(A).
That language is load-bearing. Money paid to a government in connection with a legal violation is generally not deductible. The statutory exception for restitution requires that the amount be identified as restitution in the settlement agreement itself. By writing it in, the restitution becomes an ordinary business expense. Reimbursement of the government’s investigation costs — the separate $20,000 — doesn’t get that treatment. The agreement also commits Cobblestone to help the AG’s office complete IRS Form 1098-F by year’s end, which is the reporting mechanism that makes the whole thing work.
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None of that is unusual. It’s just worth understanding that the headline restitution figure and the after-tax cost to the company are different numbers.
What to actually do about your own wash plan
Pull your card statements and find every recurring charge tied to a vehicle. Wash plans, connected-car subscriptions, remote-start services, roadside programs, telematics trials that converted quietly. Auto-renewal law only helps if you notice the charge.
If you’re a Cobblestone member, the settlement now requires — for three years — at least 25 days’ advance notice of any price change, retainable written terms at signup, trial-period disclosures, periodic renewal reminders sent between 25 and 40 days ahead, and a one-step online cancellation link. Use it if you want out.
And if you’re weighing whether an unlimited plan is worth it at all: count your actual washes over the last three months, not your intended ones. If the honest number is one a month, you’re subsidizing someone else’s daily habit. Also worth a thought — a plan that nudges you into a friction tunnel three times a week is a plan that puts a lot of spinning material against your clear coat. On dark paint especially, the swirl marks accumulate faster than the convenience is worth.
The $19 check is a rebate on inattention. The habit of reading recurring-charge terms is worth considerably more.
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