Erickson v. Dept Hum Servs

Colorado Court of Appeals·Decided July 2, 2026·No. 25CA0904·Unpublished

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

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.

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.

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

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].

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. A staff adjudicator in the Office of Appeals issued a final agency decision affirming the ALJ’s initial decision.

¶ 14 Erickson appealed the final agency decision to the Denver District Court, which affirmed.

E. Erickson’s Appeal to This Court

¶ 15 Erickson characterizes her four contentions in this appeal as follows: (1) the State Board of Human Services (the Board) lacked statutory authority to adopt the Rule, and the Rule contravenes the State Administrative Procedure Act (APA) and C.R.C.P. 56; (2) she was improperly denied the benefits of the deferred adjudication and

the deferred judgment; (3) the Rule, as applied in her case, violated her due process rights; and (4) the exhibits supporting the motion were inadmissible.

¶ 16 We first turn to Erickson’s challenge to the Board’s authority to promulgate the Rule.

II. Analysis

A. Standard of Review

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