Franklin v. State of Colorado

CourtColorado Court of Appeals
DecidedMay 21, 2026
Docket25CA0782
StatusUnpublished

This text of Franklin v. State of Colorado (Franklin v. State of Colorado) 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
Franklin v. State of Colorado, (Colo. Ct. App. 2026).

Opinion

25CA0782 Franklin v State of Colorado 05-21-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0782 City and County of Denver District Court No. 24CV620 Honorable Sarah B. Wallace, Judge

Sara Franklin,

Plaintiff-Appellant,

v.

State of Colorado and Douglas County District Court,

Defendants-Appellees.

JUDGMENT AFFIRMED

Division II Opinion by JUDGE BROWN Harris and Tow, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 21, 2026

Sara Franklin, Pro Se

Philip J. Weiser, Attorney General, Dmitry B. Vilner, Senior Assistant Attorney General, Denver, Colorado, for Defendants-Appellees ¶1 Plaintiff, Sara Franklin, appeals the district court’s order

granting the motion to dismiss filed by defendants, the State of

Colorado and the Douglas County District Court (collectively, the

State defendants). We affirm.

I. Background

¶2 In April 2012, Franklin petitioned to dissolve her marriage to

her now ex-husband in Douglas County District Court Case No.

12DR455. Almost two months later, Franklin’s ex-husband filed for

a civil protection order against her, requesting protection for himself

and their two children. After an ex parte hearing, the Douglas

County District Court (the dissolution court) issued a temporary

civil protection order and set the matter for a permanent protection

order hearing. A few days later, the ex-husband filed a motion to

restrict Franklin’s parenting time. Two days before the permanent

protection order hearing, Franklin also filed for a civil protection

order against her ex-husband.

¶3 On June 6, the dissolution court held a combined hearing on

the parties’ competing motions for civil protection orders and the

ex-husband’s motion to restrict Franklin’s parenting time. The

dissolution court denied Franklin’s motion for a civil protection

1 order, made her ex-husband’s temporary civil protection order

permanent (the PPO), and restricted her parenting time.

¶4 In April 2014, the dissolution court entered written permanent

orders dissolving the parties’ marriage. As relevant, the dissolution

court ordered that Franklin’s ex-husband would have “sole custody

and full decision-making responsibility” for the children but that

Franklin was entitled to supervised visitation. The court also

granted the ex-husband discretion to allow telephone or electronic

communication between the children and Franklin.

¶5 In August 2024, Franklin filed a complaint in Denver District

Court (the district court) asserting eight claims:

(1) Title 13, article 14, of the Colorado Revised Statutes,

providing the statutory framework for civil protection

orders, is “unconstitutional in its “‘indefinite’ lifespan

allowance” under United States v. Rahimi, 602 U.S. 680

(2024), which, according to Franklin, held “that States’

laws do not violate the federal U.S. Second Amendment

so long as disarmament is temporary.”

(2) Title 13, article 14, is unconstitutional “because it

exclusively severed the Parent-Child Relationship BOTH

2 in actuality and/or constructively on the lowest

evidentiary standard — Preponderance of the Evidence”

in violation of Santosky v. Kramer, 455 U.S. 745 (1982),

which, according to Franklin, held “that States’ law

violate[] the federal U.S. Fourteenth Amendment Due

Process protections when State actions are not at least

supported by the Clear and Convincing evidentiary

standard prior to completely and irrevocably severing

biological parental rights.”

(3) Section 24-34-805(2)(d)(I), C.R.S. 2025, requiring

compliance with the Americans with Disabilities Act in

title 14 cases, is unconstitutional because “it exclusively

sever[ed] the Parent-Child Relationship BOTH in actuality

and/or constructively on the lowest evidentiary

standard — Preponderance of the Evidence” in violation

of Santosky.

(4) Section 13-14-108, C.R.S. 2025, regarding modification

and termination of permanent civil protection orders,

“violates substantive Due Process protections in that it

3 in actuality and/or constructively via indefinitely allowing

Filings only every [two] years” and “requiring [Franklin] to

perform a fingerprint-based criminal history record check

prior to any Court consideration . . . in direct

contravention to the foundational legal principle of

innocent until proven guilty.”

(5) Title 13, article 14, violates “the federal U.S. Fourteenth

Amendment procedural Due Process Clause protections

because [Franklin] has a cognizable liberty interest in her

Biological Parent-Child Relationship existence AND the

[State defendants] deprived [Franklin of] her liberty

interest . . . without an appropriate level of process or

procedural safeguards.”

(6) Title 13, article 14, violates “the federal U.S. Fourteenth

Amendment substantive Due Process Clause protections”

because Franklin “has a fundamental right to raise and be

in relation with her biological children in a Biological

Parent-Child Relationship AND the [State defendants]

deprived [Franklin of] her fundamental right . . .

4 arbitrarily, capriciously, and without a rational basis so

egregiously that is sincerely shocks the conscious.”

(7) Title 13, article 14, is unconstitutional, “resulting in

involuntarily unconstitutional termination of the

Parent-Child Relationship resulting in Loss of Consortium

between [Franklin] and her beloved marital, minor

children,” when (i) the State defendants “were Negligent

in terminating the Parent-Child Relationship completely”;

(ii) Franklin “sustained injuries resulting from” the State

defendants’ negligence; (iii) Franklin “had a strong

Parent-Child Relationship up to and when the [State

defendants] illegally and unconstitutionally terminated”

that relationship through the entry of the PPO; and

(iv) Franklin, “[a]s a direct result . . . , has lost all rights

of consortium with [the children], manifested currently in

absolute parental alienation through continued abuse

and [the] unjustified, indefinite” PPO.

(8) Title 13, article 14, is unconstitutional, “resulting in

Parent-Child Relationship resulting in Negligent Infliction

5 of Emotional Distress,” when (i) the State defendants

“were Negligent in terminating the Parent-Child

Relationship”; (ii) the State defendants’ negligence

“created an unreasonable risk of physical harm to

[Franklin]” while she was suffering from pre-existing

medical conditions and post-traumatic stress disorder

(PTSD); (iii) the State defendants’ negligence “caused

[Franklin] to be put in fear for her own safety and such

fear is shown by physical consequences and long

continued causal emotional PTSD recurrences”; and

(iv) that “fear has caused injuries, damages, and losses.”1

¶6 Franklin asked the district court to (1) declare title 13, article

14, unconstitutional, with “enforcement cessation” and “[r]ecord

1 Franklin’s seventh and eighth claims, and possibly her sixth

claim, appear to be tort claims. In their motion to dismiss, the State defendants characterized these claims as 42 U.S.C. § 1983 claims.

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