Peo in Interest of CBB

CourtColorado Court of Appeals
DecidedMay 15, 2025
Docket24CA1711
StatusUnpublished

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

Opinion

24CA1711 Peo in Interest of CBB 05-15-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1711 City and County of Denver Juvenile Court No. 23JV31028 Honorable Laurie A. Clark, Judge

The People of the State of Colorado,

Appellee,

In the Interest of C.B.B., a Child,

and Concerning S.J.A.,

Appellant.

JUDGMENT AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division V Opinion by JUDGE SCHOCK Freyre and Sullivan, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 15, 2025

Katie McLoughlin, Acting City Attorney, Amy J. Packer, Assistant City Attorney, Denver, Colorado, for Appellee

Josi McCauley, Guardian Ad Litem

Gregory Lansky, Office of Respondent Parents’ Counsel, Aurora, Colorado, for Appellant ¶1 S.J.A. (mother) appeals the juvenile court’s judgment

adjudicating C.B.B. (the child) dependent or neglected. We affirm

the adjudication, but we reverse the disposition and remand the

case to the juvenile court for further proceedings in compliance with

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

1963, and Colorado’s ICWA statute, § 19-1-126, C.R.S. 2024.

I. Background

¶2 In November 2023, the Denver Department of Human Services

received a referral indicating that mother had tested positive for

methamphetamine and marijuana at the time she gave birth to the

child. After an initial investigation, the Department filed a petition

in dependency and neglect concerning the then-newborn child. The

Department alleged concerns about mother’s substance use; lack of

housing; pending criminal charges; medical conditions, which

included a traumatic brain injury and uncontrolled seizures; and

mental health issues, which included post-traumatic stress

disorder and bipolar disorder. The Department also noted that the

child was born with Down syndrome and needed to be on oxygen.

¶3 The juvenile court granted temporary legal custody of the child

to the Department, and the child was placed with the child’s

1 paternal grandmother. Mother denied the allegations in the petition

and requested an adjudicatory jury trial.

¶4 The juvenile court scheduled the jury trial for March 2024 but

continued it twice at mother’s request. In July 2024, mother did

not appear for the jury trial, and the court converted it to a court

trial after denying mother’s request to appear for the jury trial

virtually. At the conclusion of the trial, the court adjudicated the

child dependent or neglected under section 19-3-102(1)(b), (d), and

(e), C.R.S. 2024. The court later entered a dispositional order.

II. Mother’s Right to a Jury Trial

¶5 Mother contends that after she invoked her statutory right to a

jury trial, she never voluntarily waived it. Thus, she argues that the

juvenile court erred by converting the jury trial to a court trial. In

the alternative, she contends that her counsel was ineffective by

agreeing to proceed to a court trial. We are not persuaded.

A. Additional Background

¶6 Mother requested an adjudicatory jury trial, which the juvenile

court originally scheduled for March 2024. But mother did not

appear on the morning of trial, and her counsel requested a

continuance. The court continued the case to the afternoon and

2 said that if mother did not appear, it would convert the jury trial to

a court trial. When mother did not appear, the court converted the

case to a court trial but explained that if mother appeared on the

scheduled date, she could reassert her right to a jury trial.

¶7 Mother appeared on the scheduled date and reasserted her

right to a jury trial. The court scheduled a jury trial for three weeks

later. But mother again did not appear, and her counsel moved for

another continuance, explaining that mother had a seizure a few

days earlier. The juvenile court granted the continuance and set

the case for another pretrial conference two days later. At that

conference, mother’s counsel reported that mother was doing

better, and the court again set a jury trial at mother’s request.

¶8 On the morning of the third-scheduled jury trial, mother again

did not appear. Mother’s guardian ad litem (GAL) explained that

although mother’s counsel had talked to mother the night before,

she had been unable to reach her that morning. The court paused

the proceeding to allow mother’s counsel the opportunity “to

ascertain [mother’s] location [and] intention of attending court.”

¶9 The court recalled the case fifteen minutes later, and mother’s

counsel reported that she had spoken to mother who was

3 “purporting to not be doing well” and was “planning to call into

court.” Counsel acknowledged that it may be necessary to proceed

with a court trial but asked if the court would be willing to allow

mother to appear for the jury trial virtually. When the court denied

that request, counsel stated, “And with that, we’re in agreement

with proceeding with a court trial.” The court released the jury and

explained that mother could appear virtually for the court trial.

¶ 10 Before trial began, mother’s counsel said mother was “trying to

log in” and asked if the court could call her instead. The court

called mother twice with no answer and then allowed mother’s GAL

to step out of the courtroom to call mother. As she did so, mother’s

counsel told the court, “[W]e can get going.” After opening

statements, the court asked mother’s counsel if she had “any

updates in regards to reaching [mother],” and counsel said she did

not. The court proceeded with trial, and mother never appeared.

B. Jury Trial Waiver

¶ 11 Mother first contends that she did not waive her statutory

right to a jury trial by failing to appear for trial. We disagree.

4 1. Applicable Law and Standard of Review

¶ 12 Parents have a statutory right to a jury trial at an adjudicatory

hearing in a dependency and neglect case. § 19-3-202(2), C.R.S.

2024; People in Interest of C.C., 2022 COA 81, ¶ 11. But a parent

may expressly or impliedly waive their statutory right to a jury trial

as long as the waiver is voluntary. See C.C., ¶ 12. A person may

waive a statutory right through “freely chosen conduct that clearly

manifests an intent to relinquish the right or is inconsistent with its

assertion.” People in Interest of B.H., 2021 CO 39, ¶ 70. Moreover,

in civil cases, a jury trial is not required when “all parties

demanding trial by jury fail to appear at trial.” C.R.C.P. 39(a).

¶ 13 When a parent fails to appear for an adjudicatory jury trial,

the juvenile court “should inquire further about the parent’s

whereabouts and the circumstances concerning her absence before

converting a jury trial to a bench trial.” See C.C., ¶ 18. The court

must then determine, based on that inquiry, whether the parent’s

actions manifest an intent to relinquish their right to a jury trial or

are inconsistent with the assertion of that right. See id.; B.H., ¶ 70.

¶ 14 The waiver of a statutory right presents a mixed question of

fact and law. See B.H., ¶ 50. We therefore accept the juvenile

5 court’s factual findings if they are supported by the record and

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Quintana v. City of Westminster
56 P.3d 1193 (Colorado Court of Appeals, 2002)
In re the Marriage of Dean and Cook
2017 COA 51 (Colorado Court of Appeals, 2017)
People in Interest of M.V
2018 COA 163 (Colorado Court of Appeals, 2018)
in Interest of R.J
2019 COA 109 (Colorado Court of Appeals, 2019)
09 In re the Marriage of Zander
2019 COA 149 (Colorado Court of Appeals, 2019)
in Interest of C.B
2019 COA 168 (Colorado Court of Appeals, 2019)
in Interest of M.B
2020 COA 13 (Colorado Court of Appeals, 2020)
In re Marriage of Zander
2021 CO 12 (Supreme Court of Colorado, 2021)
in Int. of B.H
2021 CO 39 (Supreme Court of Colorado, 2021)
In re C.A.B.L.
221 P.3d 433 (Colorado Court of Appeals, 2009)
MacGregor v. Porter
354 P.2d 489 (Supreme Court of Colorado, 1960)
Elliott J. Forgette v. The People of the State of Colorado.
2023 CO 4 (Supreme Court of Colorado, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Peo in Interest of CBB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-cbb-coloctapp-2025.