of Crouch

2021 COA 3
CourtColorado Court of Appeals
DecidedJanuary 15, 2021
Docket19CA2084, Marriage
StatusPublished
Cited by14 cases

This text of 2021 COA 3 (of Crouch) 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
of Crouch, 2021 COA 3 (Colo. Ct. App. 2021).

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 January 14, 2021

2021COA3

No. 19CA2084, Marriage of Crouch — Family Law — Post- dissolution — Modification of Custody or Decision-making Responsibility

A division of the court of appeals addresses the appropriate

burden of proof to apply when considering a request to modify the

allocation of decision-making responsibility between parents for

vaccinating their children when one parent has a religious-based

objection to vaccination. The division concludes that when applying

the endangerment standard under section 14-10-131(2)(c), C.R.S.

2020, it is error for a court to impose an additional burden on the

moving parent to show substantial harm to the children. COLORADO COURT OF APPEALS 2021COA3

Court of Appeals No. 19CA2084 La Plata County District Court No. 17DR30001 Honorable Suzanne F. Carlson, Judge

In re the Marriage of

Rebecca Greene Crouch,

Appellee,

and

William Blake Crouch,

Appellant.

ORDER REVERSED AND CASE REMANDED WITH DIRECTIONS

Division V Opinion by JUDGE PAWAR J. Jones and Berger, JJ., concur

Announced January 14, 2021

The Law Firm of Lisa Ward, LLC, Lisa Ward, Donald Lawrence, Jr., Durango, Colorado, for Appellee

Willoughby & Associates, Kim Willoughby, Kaela Zihlman, Golden, Colorado, for Appellant ¶1 In Colorado, parents can elect not to vaccinate their children.

But what happens when parents divorce and one parent later has a

change of heart about vaccinating the children, while the other

maintains a religious-based objection to vaccination? In this

post-dissolution of marriage dispute, we address the appropriate

burden of proof for the district court to apply when considering the

request of William Blake Crouch (father) to modify joint medical

decision-making responsibility to allow him to vaccinate the

children, over the objection of Rebecca Greene Crouch (mother).

¶2 Following a hearing on father’s motion to modify medical

decision-making responsibility, the district court found that

remaining unvaccinated “endangers the health of the children.”

But, because mother objected to vaccinating the children based, in

part, on her religious beliefs, the court imposed an additional

burden on father “to prove substantial harm to the children” in

order to overcome “[m]other’s right to exercise religion freely.” The

court found that father failed to meet the additional burden and

denied his request to modify medical decision-making

responsibility.

1 ¶3 Father appeals the district court’s order. We reverse the order

and remand the case for further proceedings.

I. Background

¶4 Mother and father divorced in 2017, and their parenting plan

was approved by the court and incorporated into the decree. In

relevant part, the plan provides for joint medical decision-making

authority and that “[a]bsent joint mutual agreement or court order,

the children will not be vaccinated.”

¶5 In 2018, however, father had a change of heart about the

children remaining unvaccinated. Father said that his position

evolved after the parties’ divorce when he researched the issue and

concluded that the children should be vaccinated. He described a

“wake-up moment” he had when traveling for business to Seattle

while the city was experiencing a measles outbreak, and then being

afraid to be around the children after he got home out of fear of

unknowingly exposing them. He said that he travels often for work,

including to international destinations, and that he wanted to travel

to other countries with the children and believed their world would

be increasingly too small without such opportunities. He further

2 expressed concern about the children contracting

vaccine-preventable diseases and exposing others.

¶6 For her part, mother opposed vaccinating the children, in part,

because it conflicted with her religious beliefs. Father, however,

asserted that he did not hold the same religious beliefs as mother

and that the children did not adhere to restrictions dictated by

mother’s religion during his parenting time. In addition to her

religious-based objection, mother also argued that vaccines pose a

risk of side effects for the children. Specifically, because mother

has an autoimmune disease and the children all had midline

defects at birth, she asserted that vaccinations for the children are

contraindicated.

¶7 Because they were at an impasse, the parties stipulated to the

appointment of a parenting coordinator/decision-maker (PCDM) to

decide the issue. After noting the parties’ respective positions, the

PCDM declined to render a decision, stating that the issue was

outside of her expertise and likened rendering a decision on it to

“practicing medicine without a license.”

¶8 Having received no decision from the PCDM, father filed an

expedited motion with the district court seeking an order allowing

3 him to have the children vaccinated in accordance with the Centers

for Disease Control and Prevention guidelines and awarding him

sole medical decision-making responsibility. Mother responded,

objecting to vaccinations for the children and to father’s request for

sole medical decision-making responsibility, and the district court

set a hearing on the matter.

¶9 Each party testified at the hearing. Additionally, father

presented expert testimony from a physician, who was qualified as

an expert in pediatrics and vaccinations. Mother did not present

any expert testimony or any witnesses other than herself.

¶ 10 After the hearing, the court credited father’s expert’s

testimony, rejected mother’s medical-based objections, and found

that the “failure to vaccinate endangers the health of the children.”

Recognizing that mother had also asserted a religious-based

objection, however, the court went on to find that vaccination would

interfere with mother’s “right to exercise religion freely,” and

therefore imposed an “additional burden” on father “to prove

substantial harm to the children” if they remained unvaccinated.

The court ruled that father had not met this additional burden and

denied his motion to modify. The court went on to find, however,

4 that if any of the children are wounded, thereby requiring a tetanus

shot; if a disease outbreak occurs in the community preventable by

vaccination; or if the children are to travel by air or internationally,

such circumstances would constitute “substantial harm warranting

a forthwith modification of decision-making.” And because the

court found that “air travel and international travel do create

substantial harm,” it prohibited the children from air travel or

international travel unless they are vaccinated.

¶ 11 Father moved to reconsider the court’s order under C.R.C.P.

59. In denying his motion, the court clarified that it was not ruling

that the children could not be vaccinated, but only that father had

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2021 COA 3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/of-crouch-coloctapp-2021.