Parental Resp Conc ANT

CourtColorado Court of Appeals
DecidedDecember 24, 2025
Docket24CA1857
StatusUnpublished

This text of Parental Resp Conc ANT (Parental Resp Conc ANT) 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
Parental Resp Conc ANT, (Colo. Ct. App. 2025).

Opinion

24CA1857 Parental Resp Conc ANT 12-24-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1857 Jefferson County District Court No. 17DR2074 Honorable Chantel E. Contiguglia, Judge

In re the Parental Responsibilities Concerning A.N.T., a Child,

and Concerning Troy Randy Thompson,

Appellee,

and

Marissa Jeanne Roy n/k/a Marissa Garcia,

Appellant.

ORDER AFFIRMED

Division III Opinion by JUDGE GRAHAM* Lipinsky and Kuhn, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced December 24, 2025

Jennifer Anntoinette Rivera, Denver, Colorado, for Appellee

Womble Bond Dickinson (US) LLP, Kendra N. Beckwith, Elizabeth Michaels, Denver, Colorado, for Appellant

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025. ¶1 Marissa Jeanne Roy, now known as Marissa Garcia (mother),

appeals the district court’s order denying her motion to relocate the

parties’ daughter (the child) to Nevada. Mother specifically argues

that the district court erred by (1) unconstitutionally infringing on

her right to travel; (2) applying a presumption against relocation;

and (3) failing to consider all the applicable statutory factors and

making factual findings unsupported by the record. We affirm.

I. Background

¶2 After their relationship ended, mother and Troy Randy

Thompson (father) agreed to jointly parent the child, who is now

eleven. Mother and father agreed to joint decision-making, equal

parenting time, and equally divided financial responsibilities for the

child.

¶3 A few years later, mother married Louis Garcia (stepfather).

They had three children together. In 2023, mother and stepfather

moved to Nevada with their three children and stepfather’s

daughter from a previous relationship. The child remained in

Colorado, however, and father became her primary caregiver. One

year later, mother filed the motion to relocate the child to Nevada.

1 ¶4 In 2024, the district court held a hearing on the motion. After

hearing testimony and reviewing evidence from both parties, the

court concluded that it was in the child’s best interests to remain in

Colorado and denied mother’s motion to relocate the child.

II. Mother’s Right to Travel

¶5 Mother claims that the district court violated her

constitutional right to travel by “disapprov[ing]” of her move to

Nevada. Because this issue is unpreserved, we do not consider it.

¶6 As father points out — and mother concedes — mother did not

raise her right to travel argument at the hearing. In civil cases like

this one “[w]e do not consider constitutional issues raised for the

first time on appeal.” McGihon v. Cave, 2016 COA 78, ¶ 16.

¶7 Mother argues that, by basing its decision on its disapproval of

her move to Nevada, the court denied her motion on grounds that

neither she nor father raised and thereby deprived her of an

opportunity to raise her constitutional argument before the ruling.

But the record shows that the court didn’t base its decision on

disapproval of mother’s move.

¶8 During its extensive consideration of the statutory factors, the

district court only mentioned mother’s move twice and never as a

2 basis for its denial of mother’s motion. The court’s only expression

of concern over mother’s move related to how “suddenly it seemed

to the Court and through [father’s] testimony that the child

suddenly came into his primary care.” This hardly constitutes a

ruling beyond the scope of the parties’ arguments, as mother

claims.

¶9 Thus, since the district court did not rule on mother’s right to

travel and mother did not raise this constitutional argument at the

hearing, we do not review it.

III. Presumption Against Relocation

¶ 10 Mother next argues that the district court erred by applying a

presumption against relocation. It did not apply such a

presumption, however.

A. Legal Principles and Standard of Review

¶ 11 When ruling on a motion to relocate a child, courts consider

several statutory factors to determine whether the move “is in the

3 best interests of the child.”1 § 14-10-129(2)(c), C.R.S. 2025; see

§ 14-10-124(1.5)(a), C.R.S. 2025. Because both parents have an

equal burden of demonstrating what is in the child’s best interests,

courts may not create a presumption in favor of either parent when

adjudicating a majority time parent’s motion to remove the child

from the state. See In re Marriage of Ciesluk, 113 P.3d 135, 137,

149 (Colo. 2005).

¶ 12 We review a district court’s best interests analysis under

section 14-10-129(2)(c) for an abuse of discretion. Ciesluk, 113

P.3d at 148. “A court abuses its discretion when its decision is

manifestly arbitrary, unreasonable, or unfair, or when it

misconstrues or misapplies the law.” In re Marriage of Dale, 2025

COA 29, ¶ 7 (cert. granted in part July 21, 2025). A court has broad

discretion in deciding parenting time and “every presumption that

1 The statutory best interests analysis applies when (1) the

relocating party is already the primary parent or (2) there is equal parenting time, but the move would make the relocating party the primary parent. See In re Marriage of DeZalia, 151 P.3d 647, 650 (Colo. App. 2006). Though not addressed by the parties, we consider mother and father to have had equal parenting time when mother filed her motion to relocate, as they stipulated in the parenting plan in effect at that time.

4 supports upholding the court’s decision will be exercised.” In re

Marriage of Hatton, 160 P.3d 326, 330 (Colo. App. 2007).

B. The District Court Didn’t Apply a Presumption Against Relocation

¶ 13 Mother again directs us to the district court’s comments about

her move to Nevada as evidence that the court allegedly applied a

presumption against relocation. But as discussed previously, the

court didn’t disapprove of her move — only its abrupt impact on the

child when father suddenly became the child’s primary caregiver.

¶ 14 Mother also highlights the district court’s reluctance to disrupt

the child’s academic growth. The court cited testimony from her

teachers and found that she was “working diligently towards an

[individualized education program] and overcoming the growth and

issues that she has.” That the court also said, “[n]ot to suggest that

the Nevada [school] wouldn’t do the same,” does not prove that the

court kept the child in Colorado based on a presumption against

relocation. On the contrary, the court’s observation appeared to

assign equal opportunity to the child in the Nevada and Colorado

school systems.

5 ¶ 15 And the court properly evaluated the statutory factors —

which include “[t]he educational opportunities for the child at the

existing location and at the proposed new location” — to conclude

that staying in Colorado was in the child’s best interests. § 14-10-

129(2)(c)(IV). Indeed, one of the statutory factors is “[a]ny

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Related

In Re the Marriage of McNamara
962 P.2d 330 (Colorado Court of Appeals, 1998)
In Re the Marriage of Ciesluk
113 P.3d 135 (Supreme Court of Colorado, 2005)
Marriage of DeZalia v. DeZalia
151 P.3d 647 (Colorado Court of Appeals, 2006)
McGihon v. Cave
2016 COA 78 (Colorado Court of Appeals, 2016)

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Bluebook (online)
Parental Resp Conc ANT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parental-resp-conc-ant-coloctapp-2025.