Peo in Interest of AMI

CourtColorado Court of Appeals
DecidedJuly 24, 2025
Docket24CA1795
StatusUnpublished

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

Opinion

24CA1795 Peo in Interest of AMI 07-24-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1795 City and County of Denver Juvenile Court No. 23JV30162 Honorable Laurie A. Clark, Judge

The People of the State of Colorado,

Appellee,

In the Interest of A.M.I. and M.M.I., Children,

and Concerning F.M.A.N.,

Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division VII Opinion by JUDGE PAWAR Lipinsky and Lum, JJ., concur

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

Katie McLouglin, Acting City Attorney, Christina R. Kinsella, Assistant City Attorney, Denver, Colorado, for Appellee

Debra W. Dodd, Guardian Ad Litem

Elizabeth A. McClintock, Office of Respondent Parent’s Counsel, Colorado Springs, Colorado, for Appellant ¶1 In this dependency and neglect proceeding, F.M.A.N. (mother)

appeals the juvenile court’s order revoking her deferred

adjudication and adjudicating A.M.I. and M.M.I. (the children)

dependent or neglected. We conclude that the Denver Department

of Human Services did not meet its burden to show that mother

failed to sufficiently comply with the terms of her deferred

adjudication agreement. Accordingly, we reverse and remand with

directions.

I. Background

¶2 In January 2023, the Department received a referral

concerning the then-seven and five-year-old children, who were

living with mother at a homeless shelter. The Department opened

an assessment to work with the family on a voluntary basis because

the shelter’s staff members were concerned about possible medical

and educational neglect, as well as a lack of supervision.

¶3 Two months later, after mother was arrested for refusing to

leave the shelter, the Department obtained an oral order for

temporary legal custody of the children and placed them with their

maternal grandparents.

1 ¶4 The Department then filed a petition in dependency and

neglect. In addition to its concerns about possible neglect while the

family was living at the homeless shelter, the Department alleged

that mother was previously involved with the Department and had a

history of mental health issues.

¶5 In July 2023, mother admitted paragraph 5(e) of the petition,

in which the Department alleged that the children were homeless,

without proper care, or not domiciled with their parent, guardian,

or legal custodian through no fault of mother. The parties entered

into an agreement (the deferred adjudication agreement) to defer the

adjudication for at least six months as long as mother complied

with several specified terms, including completing a psychological

evaluation, obtaining stable housing, mitigating the Department’s

safety concerns, and understanding the children’s needs.

¶6 Four months later, mother filed a motion to return the

children home, asserting that she had complied with the terms of

the deferred adjudication agreement and that she was a fit parent.

The juvenile court set a hearing on mother’s motion but continued

it at mother’s request. In the meantime, the Department filed a

motion to revoke the deferred adjudication on the grounds that

2 mother had failed to sufficiently comply with the deferred

adjudication agreement.

¶7 In April 2024, the juvenile court began a contested hearing

regarding the “return home [motion] and the revocation of the

deferred [adjudication].” The hearing lasted seven days over four

months. After hearing the evidence, the court entered an oral order

granting the Department’s motion to revoke the deferred

adjudication and denying mother’s motion to return the children

home. The court later issued a written adjudicatory and

dispositional order.

II. Discussion

¶8 Mother contends that the juvenile court erred by misapplying

the law governing deferred adjudications. Specifically, she argues

that the Department did not meet its burden to show that she failed

to sufficiently comply with the terms of her deferred adjudication

agreement, and thus, the court’s findings were unsupported by the

record. She also argues that the court failed to follow People in

Interest of N.G., 2012 COA 131, which requires a court to reconsider

the status of the children — i.e., whether they are dependent or

neglected — before revoking a deferred adjudication. Finally,

3 mother argues that the juvenile court misapplied N.G. because it

did not make any findings about whether her Troxel presumption —

the presumption that she was acting in the children’s best interests

— had been overcome. See Troxel v. Granville, 530 U.S. 57, 66

(2000).

¶9 We agree with mother that the court’s findings that mother did

not sufficiently comply with the deferred adjudication agreement

lacked record support and we therefore reverse the adjudication.

Because we reverse on this basis, we do not address mother’s other

arguments.

A. Legal Authority and Standard of Review

¶ 10 In dependency and neglect proceedings, an adjudication

represents the juvenile court’s determination that state intervention

is necessary to protect a child and that the family requires

rehabilitative services to safely care for the child. People in Interest

of J.G., 2016 CO 39, ¶ 16. Typically, before adjudicating a child

dependent or neglected, the court must hold a hearing at which the

department is required to prove the allegations in the petition by a

preponderance of the evidence. Id.; see also § 19-3-505, C.R.S.

2024. Alternatively, the court may accept a parent’s admission at

4 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.

¶ 11 When a parent admits that a child is dependent or neglected,

the parent may defer adjudication by continuing the adjudicatory

hearing. Section 19-3-505(5), provides the process for doing so.

Specifically, when a parent admits the children are dependent or

neglected, a deferred adjudication allows a juvenile court, with all

parties’ consent, to continue the adjudicatory hearing for six

months and to defer entry of judgment. § 19-3-505(5)(a)-(b).

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

continue the hearing for another six months, after which the court

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

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

question of fact and law because it requires the application of the

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.

5 B. The Department Did Not Prove That Mother Failed to Sufficiently Comply with the Deferred Adjudication Agreement

¶ 13 Consistent with the deferred adjudication agreement, mother

was entitled to an “evidentiary hearing [on] whether or not [she had]

sufficiently complied with the terms of this deferred adjudication.”

At the hearing, the Department bore the burden to prove, by a

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Related

Troxel v. Granville
530 U.S. 57 (Supreme Court, 2000)
Atlantic & Pacific Insurance Co. v. Barnes
666 P.2d 163 (Colorado Court of Appeals, 1983)
Boulder Plaza Residential, LLC v. Summit Flooring, LLC
198 P.3d 1217 (Colorado Court of Appeals, 2008)
in Interest of S.R.N.J-S
2020 COA 12 (Colorado Court of Appeals, 2020)
In re Parental Responsibilities Concerning B.R.D.
2012 COA 63 (Colorado Court of Appeals, 2012)
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 AMI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-ami-coloctapp-2025.