Peo in Interest of AH

CourtColorado Court of Appeals
DecidedJuly 10, 2025
Docket25CA0304
StatusUnpublished

This text of Peo in Interest of AH (Peo in Interest of AH) 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
Peo in Interest of AH, (Colo. Ct. App. 2025).

Opinion

25CA0304 Peo in Interest of AH 07-10-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0304 Arapahoe County District Court No. 22JV486 Honorable Shay K. Whitaker, Judge

The People of the State of Colorado,

Appellee,

In the Interest of Ad.H. and Ar.H., Children,

and Concerning R.B.,

Appellant.

JUDGMENT AFFIRMED

Division IV Opinion by JUDGE MEIRINK Freyre and Gomez, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced July 10, 2025

Ron Carl, County Attorney, Erinn Walz, Assistant County Attorney, Aurora, Colorado, for Appellee

Brittany Radic, Guardian Ad Litem

Patrick R. Henson, Office for Respondent Parent’s Counsel, Chelsea A. Carr, Office for Respondent Parent’s Counsel, Denver, Colorado, for Appellant ¶1 In this dependency and neglect proceeding, R.B. (mother)

appeals the juvenile court’s judgment revoking her deferred

adjudication and adjudicating Ad.H. and Ar.H. (the children)

dependent and neglected. We affirm.

I. Background

¶2 The Arapahoe County Department of Human Services (the

Department) received a referral raising concerns about mother’s

substance use and the condition of her home. The Department

contacted mother who agreed to take a drug test. Upon receipt of a

positive result, the Department called mother and learned she was

in the process of leaving the state with the children. The

Department then filed a petition in dependency or neglect.

¶3 Three months later, mother and the Department agreed to a

deferred adjudication. As part of the deferred adjudication

agreement, mother admitted that the children were dependent and

neglected because (1) they were without parental care through the

acts or omissions of the parent; (2) their environment was injurious

to their welfare; and (3) the parent, guardian, or legal custodian

failed or refused to provide proper or necessary subsistence,

educational, or medical care. See § 19-3-102(1)(b)-(d), C.R.S. 2024.

1 ¶4 As a condition of the deferred adjudication, mother agreed to

comply with a treatment plan that required her to (1) maintain

contact with the caseworker; (2) engage in parenting time; (3)

develop protective parenting capacity; (4) participate in therapy and

address substance abuse issues; (5) maintain stable housing; and

(6) maintain employment and stable income. The deferred

adjudication agreement also stated that if mother had four or more

positive drug tests and/or six or more missed tests, it would be an

“independent ground” for entry of adjudication, regardless of her

progress with the treatment plan.

¶5 The Department later moved to revoke mother’s deferred

adjudication, arguing that mother’s failure to comply with the

treatment plan and substance monitoring warranted entry of a

judgment adjudicating the children dependent and neglected. The

juvenile court held an evidentiary hearing and adjudicated the

children dependent and neglected.

II. Treatment Plan Compliance

¶6 Mother argues that the juvenile court erred by revoking her

deferred adjudication because she complied with her treatment

plan. We are not persuaded.

2 A. Applicable Law and Standard of Review

¶7 “The purpose of an adjudicatory hearing is to determine

whether the factual allegations in the dependency and neglect

petition are supported by a preponderance of the evidence, and

whether the status of the subject child or children warrants

intrusive protective or corrective state intervention into the familial

relationship.” People in Interest of A.M., 786 P.2d 476, 479 (Colo.

App. 1989). Alternatively, the juvenile court may accept a parent’s

admission at an adjudicatory hearing. People in Interest of J.W. v.

C.O., 2017 CO 105, ¶ 32. The “court’s acceptance of [a parent’s]

admission establishe[s] the status of the children as dependent or

neglected.” Id.

¶8 Section 19-3-505(5), C.R.S. 2024, provides for a process that

courts and practitioners often refer to as “deferred adjudication.”

Specifically, it allows a juvenile court, with the consent of all

parties, to continue the adjudicatory hearing for up to six months

and to defer entry of judgment when a parent admits the children

are dependent or neglected. § 19-3-505(5)(a)-(b). Following the

initial six-month period, the juvenile court may continue the

3 hearing for another six months, after which the court must dismiss

or sustain the petition.1 § 19-3-505(5)(b).

¶9 At such time, the juvenile court may consider the parent’s

admission made when the deferral was entered, along with any

evidence related to the progress the parent has made and the

ongoing needs and status of the child. See People in Interest of

N.G., 2012 COA 131, ¶¶ 23, 26-27.

¶ 10 Whether a child is dependent or neglected presents a mixed

question of fact and law because it requires the application of

statutory criteria to evidentiary facts. See People in Interest of E.R.,

2018 COA 58, ¶ 5. We review the court’s factual findings for clear

error but review de novo its legal conclusions based on those facts.

People in Interest of A.S.L., 2022 COA 146, ¶ 8.

1 We acknowledge that the revocation hearing was held outside of

the twelve-month timeframe permitted by section 19-3-505(5)(b). But a juvenile court does not lose jurisdiction by failing to conduct the hearing within this statutory timeframe. See People in Interest of A.W., 74 P.3d 497, 498-99 (Colo. App. 2003). And, because mother does not raise the juvenile court’s noncompliance with the statutory timeframe as an issue on appeal, we will not address it further.

4 B. Analysis

¶ 11 The juvenile court found that mother violated the terms of the

deferred adjudication agreement by not complying with the

parenting time component of her treatment plan. Specifically, the

court found that mother (1) missed fourteen out of twenty-nine

visits in the six months prior to the revocation hearing; (2) did not

have a reasonable explanation for the missed visits; and (3) violated

the parenting time safety plan.

¶ 12 The record supports the court’s findings. Mother’s parenting

time coach testified about mother’s missed visits. She also

described how mother violated her safety plan by changing the

location of her unsupervised community visit without notice and by

having an unapproved third party present. The parenting time

coach opined that, due to the “significant amount” of missed visits,

mother was only partially compliant with this component of her

treatment plan.

¶ 13 The caseworker similarly opined that mother was not

compliant with the parenting time component of her treatment

plan. She testified about how mother’s missed visits caused “some

breaking down” of her relationship with the children. The

5 caseworker acknowledged that mother explained her missed visits

but did not provide the caseworker with any supportive

documentation.

¶ 14 Even so, mother asserts that she substantially complied with

her treatment plan because she communicated with the

caseworker, obtained stable housing and employment, and

completed an outpatient sober living program.

¶ 15 The juvenile court acknowledged the progress mother made on

some components of her treatment plan, including her contact with

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Related

People ex rel. N.G.
2012 COA 131 (Colorado Court of Appeals, 2012)
People ex rel. J.W. v. C.O.
2017 CO 105 (Supreme Court of Colorado, 2017)

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Peo in Interest of AH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-ah-coloctapp-2025.