In re the Marriage of Stockwell

2019 COA 96
CourtColorado Court of Appeals
DecidedJune 27, 2019
Docket17CA1482
StatusPublished
Cited by2 cases

This text of 2019 COA 96 (In re the Marriage of Stockwell) 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
In re the Marriage of Stockwell, 2019 COA 96 (Colo. Ct. App. 2019).

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 June 27, 2019

2019COA96

No. 17CA1482, In re the Marriage of Stockwell — Family Law — Parental Responsibilities; American Indian Law — ICWA — Placement of Indian Children — Foster Care or Preadoptive Placements

In a case concerning the allocation of parental responsibilities

for a child (APR), a division of the court of appeals considers

whether the APR triggered the requirements of the federal Indian

Child Welfare Act of 1978 (ICWA). The division clarifies that (1) a

legal father under Colorado law is not necessarily a “parent” for

purposes of ICWA and (2) an APR to a legal father who does not

qualify as a “parent” under ICWA is a “child custody proceeding”

subject to ICWA.

Because the APR to the legal father here constituted a child

custody proceeding and the district court did not comply with ICWA, we reverse the order denying the mother’s motion to vacate

the APR order, and we remand for further proceedings. COLORADO COURT OF APPEALS 2019COA96

Court of Appeals No. 17CA1482 City and County of Denver District Court No. 12DR1367 Honorable Catherine A. Lemon, Judge

In re the Marriage of

Joseph Cody Stockwell,

Appellee,

and

Jennifer Lynn Dees,

Appellant.

ORDER REVERSED AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE NAVARRO Richman and Welling, JJ., concur

Announced June 27, 2019

Joseph Cody Stockwell, Pro Se

Jennifer Lynn Dees, Pro Se ¶1 In this proceeding concerning the allocation of parental

responsibilities (APR) for L.D-S., Jennifer Lynn Dees, the child’s

mother, appeals the district court’s order denying her motion to

vacate a 2013 order giving majority parenting time to Joseph Cody

Stockwell, the child’s legal but not biological father. Dees contends

that the court erred because it issued the APR order without first

inquiring into the child’s possible Indian heritage as required by the

Indian Child Welfare Act of 1978 (ICWA), 25 U.S.C. §§ 1901 to 1963

(2018). Dees is right. In agreeing with her, we clarify that (1) a

legal father under Colorado law is not necessarily a “parent” for

purposes of ICWA and (2) an APR to a legal father who does not

qualify as a “parent” under ICWA is a “child custody proceeding”

under ICWA.

¶2 Because the APR to Stockwell here constituted a child custody

proceeding and the court did not comply with ICWA, we reverse the

order denying Dees’s motion and remand for further proceedings.

I. Factual and Procedural History

¶3 L.D-S. was born during the marriage between Dees and

Stockwell. That marriage has since been dissolved. Although

Stockwell is not L.D-S.’s biological father, he was declared his legal

1 father under the paternity presumption in section 19-4-105(1)(a),

C.R.S. 2018. On October 2013, the district court entered an APR

order that named Stockwell the primary residential parent for L.D-

S. and limited Dees’s parenting time to weekends. Over the next

few years, the court expanded Dees’s parenting time to include

holidays, school breaks, and two weeks of summer vacation.

¶4 In 2015, Dees asked the court to set aside the October 2013

APR order. She alleged that she had obtained a DNA test result

from L.D-S.’s biological father that would rebut Stockwell’s

paternity presumption. A magistrate denied her motion, and the

district court adopted the magistrate’s order.

¶5 In 2017, Dees filed a pro se motion titled “Motion for 25 U.S.C.

1914 ‘ICWA’ Violations,” arguing that federal law required L.D-S. to

be returned to her care (hereinafter, ICWA motion). She attached to

the ICWA motion various orders (including the October 2013 APR

order) and a letter asking the district court to invalidate all

parenting orders, return L.D-S. to her custody, and comply with

ICWA. She asserted in her letter that L.D-S. was “Choctaw and

Wailaki on my side only” and that the APR to Stockwell was a

“foster care placement.” The court denied the motion as untimely.

2 II. ICWA Compliance

A. Basic Principles

¶6 ICWA is intended to protect and preserve Indian tribes and

their resources, and to protect Indian children who are members of

or are eligible for membership in an Indian tribe. 25 U.S.C.

§ 1901(2), (3) (2018); People in Interest of M.V., 2018 COA 163, ¶ 10.

ICWA recognizes that Indian tribes have a separate interest in

Indian children that is equivalent to, but distinct from, parental

interests. M.V., ¶ 10. Thus, in a proceeding in which ICWA may

apply, tribes must have a meaningful opportunity to participate in

determining whether a child who is a subject of the proceeding is an

Indian child and to be heard on the issue of the applicability of

ICWA. B.H. v. People in Interest of X.H., 138 P.3d 299, 303 (Colo.

2006).

¶7 ICWA applies when an Indian child is the subject of a “child

custody proceeding,” which includes any action that could

culminate in “foster care placement.” 25 U.S.C. § 1903(1) (2018);

25 C.F.R. § 23.2 (2018); People in Interest of K.G., 2017 COA 153,

¶ 14. An “Indian child” is any unmarried person who is under age

eighteen and is either (1) a member of an Indian tribe or (2) eligible

3 for membership in an Indian tribe and is the biological child of a

member of an Indian tribe. 25 U.S.C. § 1903(4). Under ICWA, a

tribe is entitled to intervene in child custody proceedings involving

its children, and a tribal court is the preferred jurisdiction for such

proceedings. K.G., ¶ 6.

¶8 At the start of every emergency, voluntary, or involuntary child

custody proceeding, the district court must ask each participant

whether he or she knows or has reason to know that the child is an

Indian child. 25 C.F.R. § 23.107(a) (2018); K.G., ¶ 21. All

responses should be on the record. 25 C.F.R. § 23.107(a).

¶9 It is “critically important” that the court inquire into whether a

child is an Indian child because, if an inquiry is not made, “a

child-custody proceeding may not comply with ICWA and thus may

deny ICWA protections to Indian children and their families.”

Bureau of Indian Affairs, Guidelines for Implementing the Indian

Child Welfare Act 11 (Dec. 2016), https://perma.cc/3TCH-8HQM;

see also People in Interest of C.A., 2017 COA 135, ¶ 17.

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2019 COA 96, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-marriage-of-stockwell-coloctapp-2019.