Elken v. Bain

2025 COA 83
CourtColorado Court of Appeals
DecidedOctober 16, 2025
Docket24CA0590
StatusPublished

This text of 2025 COA 83 (Elken v. Bain) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elken v. Bain, 2025 COA 83 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY October 16, 2025

2025COA83

No. 24CA0590, Elken v. Bain — Family Law — Parents and Children — Assisted Reproduction — Embryos — Unmarried Parties

In this declaratory judgment action regarding the disposition

of pre-embryos, a division of the court of appeals concludes that the

multi-factor balancing test adopted by the Colorado Supreme Court

in In re Marriage of Rooks, 2018 CO 85 — a framework developed in

the context of a dissolution of marriage proceeding — applies to a

dispute between nonmarried individuals. The division also

concludes that the district court correctly applied the Rooks

framework to a situation in which one party seeks to implant the

pre-embryos to have a genetic child, while the other party seeks to

donate them to avoid sharing a genetic child with the first party.

Finally, the division concludes that the district court did not abuse its discretion in balancing the Rooks factors. Accordingly, the

division affirms the judgment. COLORADO COURT OF APPEALS 2025COA83

Court of Appeals No. 24CA0590 City and County of Denver District Court No. 23CV30717 Honorable Mark T. Bailey, Judge

Rachael Elken,

Plaintiff-Appellant,

v.

Tyler Bain,

Defendant-Appellee.

JUDGMENT AFFIRMED

Division I Opinion by JUDGE BROWN J. Jones and Yun, JJ., concur

Announced October 16, 2025

Burg Simpson Eldredge Hersh & Jardine, P.C., Michael S. Burg, D. Dean Batchelder, Patrick M. Sweet, Elizabeth N. Torma, Englewood, Colorado, for Plaintiff-Appellant

Tyler Bain, Pro Se ¶1 Plaintiff, Rachael Elken, appeals the district court’s judgment

ordering that she and defendant, Tyler Bain, donate four

cryogenically frozen pre-embryos they created before their

relationship ended. Elken contends that the district court

(1) misapplied the multi-factor balancing test developed by the

Colorado Supreme Court in In re Marriage of Rooks, 2018 CO 85;

and (2) abused its discretion in balancing the Rooks factors.

¶2 In resolving this case, we first conclude that the Rooks

framework, which was developed in the context of a dissolution of

marriage proceeding, applies to a dispute between nonmarried

individuals over the disposition of pre-embryos created from their

genetic material. We also conclude that the district court correctly

applied the Rooks factors to a situation in which one party seeks to

implant the pre-embryos to have genetic children, while the other

party seeks to donate them to avoid sharing a genetic child with the

first party. Finally, we conclude that the court did not abuse its

discretion in weighing the Rooks factors in this case. Accordingly,

we affirm the judgment.

1 I. Background

¶3 Rachael Elken and Tyler Bain began a romantic relationship in

2018. Bain had two children from a previous marriage, while Elken

had none. During their relationship, Elken and Bain wanted to

start a family together — Bain even reversed his vasectomy, and

Elken purchased a home large enough to accommodate Bain’s two

children and any future children they might have together.

¶4 After unsuccessfully trying to conceive children naturally,

Elken contacted the Colorado Center for Reproductive Medicine

(CCRM). Following a discussion of the various options, Bain and

Elken decided to use in vitro fertilization (IVF) to combine their

genetic material and create pre-embryos.

¶5 Bain and Elken signed a CCRM form agreement titled

“Disposition of Embryos and Declaration of Intent.” The CCRM

agreement clarified what the parties wanted CCRM to do with the

pre-embryos in four situations: Elken’s death; Bain’s death; the

parties’ simultaneous deaths; and “Divorce, Dissolution of

Relationship, or Discontinuation of IVF Treatment.” As relevant

here, in the event their relationship ended, Elken and Bain agreed

to the following option: “A court decree, settlement agreement, or

2 written instructions signed by each party and notarized will be

presented to [CCRM] directing use to achieve a pregnancy in one of

us or anonymously donate the embryos to another couple for

reproductive purposes . . . .”

¶6 CCRM created four viable pre-embryos from Elken’s and

Bain’s genetic material. A few months later, an argument between

Elken and Bain escalated into physical violence. The details of the

incident are disputed, but the altercation led to the end of their

relationship. Bain then independently contacted CCRM to request

that it “stop the [IVF] process.”

¶7 Over the next several months, the parties could not reach an

agreement regarding the fate of their pre-embryos. In March 2023,

Elken filed a complaint for declaratory relief, seeking possession of

the pre-embryos under the CCRM agreement so that she could use

them to become a genetic parent.

¶8 Following a two-day bench trial, the district court made

detailed findings of fact and carefully balanced the parties’

respective interests under the Rooks factors. The court concluded

that “Mr. Bain’s interest in procreative autonomy outweighs Ms.

Elken’s interest in the use of these four [pre-]embryos” and ordered

3 that the pre-embryos be anonymously donated to another couple

for reproductive purposes. The court stayed its judgment pending

this appeal.

II. The Rooks Framework Applies to Nonmarried Individuals Who Have Created Pre-Embryos

¶9 Rooks involved a divorcing couple’s dispute over the

disposition of their cryogenically frozen pre-embryos. Rooks,

¶¶ 2-4. Although the matter could have been characterized simply

as a dispute over “the equitable division of marital property in a

divorce proceeding,” the supreme court acknowledged that “the

parties’ competing interests in the disputed pre-embryos derive

from constitutional rights in the realm of reproductive choice,” not

from the right to marry. Id. at ¶ 35. Indeed, “[t]he decision whether

to bear or beget a child is a constitutionally protected choice.” In re

Romero, 790 P.2d 819, 822 (Colo. 1990). Consequently, deciding

the fate of the pre-embryos after a relationship ends “presents

difficult issues of procreational autonomy for which there are no

easy answers because it pits one spouse’s right to procreate directly

against the other spouse’s equivalently important right to avoid

procreation, and because the fundamental liberty and privacy

4 interests at stake are deeply personal and emotionally charged.”

Rooks, ¶ 3.

¶ 10 Even though the parties here were never married, they agree

that the Rooks framework should apply to the dispute over their

pre-embryos. We do too. Notwithstanding the supreme court’s

characterization of the pre-embryos in Rooks as “marital property of

a special character,” it was individual “autonomy over decisions

involving reproduction” that animated the balancing test the court

adopted to resolve the dispute. Id. at ¶ 64.

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Bluebook (online)
2025 COA 83, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elken-v-bain-coloctapp-2025.