Erickson v. Dept Hum Servs

CourtColorado Court of Appeals
DecidedJuly 2, 2026
Docket25CA0904
StatusUnpublished

This text of Erickson v. Dept Hum Servs (Erickson v. Dept Hum Servs) 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
Erickson v. Dept Hum Servs, (Colo. Ct. App. 2026).

Opinion

25CA0904 Erickson v Dep’t of Human Services 07-02-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0904 City and County of Denver District Court No. 23CV33680 Honorable Michael W.V. Angel, Judge

Erika Erickson,

Plaintiff-Appellant,

v.

Colorado Department of Human Services,

Defendant-Appellee.

JUDGMENT AFFIRMED

Division V Opinion by JUDGE LIPINSKY Yun and Schutz, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced July 2, 2026

Byram Law, P.C., Elle J. Byram, Broomfield, Colorado, for Plaintiff-Appellant

Philip J. Weiser, Attorney General, Kendra Yates, Assistant Attorney General II, Jennifer L. Carty, Senior Assistant Attorney General, Denver, Colorado, for Defendant-Appellee ¶1 Erika Erickson appeals the district court’s affirmance of the

administrative law judge’s (ALJ) entry of summary judgment against

her in Erickson’s administrative appeal of the findings of the

Boulder County Department of Housing and Human Services (the

County) that she abused or neglected her minor children. We

affirm.

I. Background

A. The Dependency and Neglect Proceeding

¶2 In July 2022, the County filed a petition in dependency and

neglect (the petition) against Erickson, alleging, among other facts,

that her minor children were “mistreat[ed] or abused” and “lack[ed]

proper parental care.” In paragraph 4(c) of the petition, the County

specifically alleged that the children were dependent and neglected

because their “environment [was] injurious to their welfare.” And in

amended paragraph 10(a) of the petition, the County specifically

alleged that the “family [was] in need of support[].” (We refer to

paragraph 4(c) and amended paragraph 10(a) jointly as the “limited

admissions.”)

¶3 On January 17, 2023, the County and Erickson entered into a

stipulated continued adjudication (the deferred adjudication) under

1 section 19-3-505(5), C.R.S. 2025. The court then entered a

stipulated continued adjudication order, in which, among other

provisions, it found that Erickson “voluntarily and knowingly” made

the limited admissions by entering into the deferred adjudication.

¶4 In June 2023, after Erickson successfully completed the terms

of the deferred adjudication, the court dismissed the petition and

concluded the dependency and neglect proceeding.

B. The Criminal Child Abuse Case

¶5 In August 2022, Erickson was charged with criminal child

abuse under section 18-6-401(7), C.R.S. 2025, based on injuries

that her child G.E. sustained. The summons and complaint (the

complaint) served on Erickson in the criminal case cited her

knowingly unreasonable placement of G.E. “in a situation which

posed a threat of injury to [the] child’s life or health and resulted in

an . . . injury” to him. Erickson subsequently agreed to a

twelve-month deferred judgment under which she pleaded guilty to

child abuse.

¶6 Erickson satisfied the terms of the deferred judgment. As a

consequence, her guilty plea was withdrawn, and her criminal case

was dismissed.

2 C. Erickson Is Added to the Trails Database

¶7 The Colorado Department of Human Services (the State

Department) maintains a statewide child abuse and neglect registry

called “Trails.” Romero v. Colo. Dep’t of Hum. Servs., 2018 COA 2,

¶ 32, 417 P.3d 914, 921. The County notified Erickson in a letter

dated August 8, 2022 (the notice letter), that she had been

identified as the person responsible for five incidents of child abuse

or neglect — four “Environment Injurious” incidents and one

“Physical” incident. In the notice letter, the County said that

Erickson’s “name w[ould] be maintained” in Trails “as a person

responsible” for the five incidents of child abuse or neglect. The

County explained in the notice letter that “agencies provided by law

when making decisions regarding child protection referrals and

assessments” may access Trails and that “certain employers and

agencies are required, or allowed, by law to request a check of Trails

when screening individuals for positions that involve the care,

treatment, or supervision of children.” In addition, the County

advised Erickson of her right to appeal her inclusion in Trails.

3 D. Erickson’s Initial Appeals

¶8 Erickson appealed her inclusion in Trails. Her appeal was

referred to the Office of Administrative Courts. The State

Department — the adverse party in Erickson’s appeal — filed a

notice of issues that recited the factual basis for the County’s

determination that Erickson was “a person responsible for an

incident of child abuse or neglect.”

¶9 After Erickson responded to the notice of issues, the State

Department filed a summary judgment motion (the motion)

supported by four exhibits — (1) the notice letter; (2) certified court

records, including the complaint and the police incident report in

her criminal case; (3) a certified copy of the deferred judgment; and

(4) a certified copy of the deferred adjudication.

¶ 10 In the motion, the State Department argued there was no

genuine issue of material fact in this case because the deferred

adjudication and the deferred judgment “ar[ose] out of the same

factual basis as the founded finding” in Trails. The State

Department said that, under Department of Human Services Rule

7.111(H), 12 Code Colo. Regs. 2509-2 (the Rule), the deferred

adjudication and the deferred judgment constituted Erickson’s

4 admission to “the factual basis of the finding of responsibility for

child abuse or neglect” and were therefore “conclusive evidence of

[Erickson’s] responsibility for child abuse or neglect to support a

motion for summary judgment.”

¶ 11 The Rule says, in its entirety,

The following circumstances shall be considered to be admissions to the factual basis of the finding of responsibility for child abuse or neglect entered into the state automated case management system and shall be considered to be conclusive evidence of the person’s responsibility for child abuse or neglect to support a motion for summary judgment submitted to the Office of Administrative Courts:

1. When a Dependency and Neglect Petition has been adjudicated against or a deferred adjudication entered against the Appellant on the basis of Sections 19-3-103 or 19-3-102(1)(a), (b), or (c), C.R.S.[ 2025], arising out of the same factual basis as the founded finding in [Trails];

2. The Appellant has been found guilty of child abuse, or has pled guilty or nolo contendere to child abuse as part of any plea agreement including, but not limited to, a deferred judgment agreement, arising out of the same factual basis as the founded finding in [Trails].

5 Dep’t of Hum. Servs. Rule 7.111(H), 12 Code Colo. Regs. 2509-2

(emphases added).

¶ 12 Erickson responded to the motion by asserting the same

arguments she raises on appeal. Significantly, she did not deny the

limited admissions or any other facts supporting the motion;

nowhere in her response did she attempt to establish that disputed

issues of material fact precluded the entry of summary judgment.

¶ 13 In September 2023, an ALJ at the Office of Administrative

Courts made an initial decision to grant the motion. Erickson filed

exceptions to the initial decision with the State Department’s Office

of Appeals.

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Erickson v. Dept Hum Servs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erickson-v-dept-hum-servs-coloctapp-2026.