Peo in Interest of EN

CourtColorado Court of Appeals
DecidedMay 1, 2025
Docket24CA1969
StatusUnpublished

This text of Peo in Interest of EN (Peo in Interest of EN) 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.

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Peo in Interest of EN, (Colo. Ct. App. 2025).

Opinion

24CA1969 Peo in Interest of EN 05-01-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1969 Jefferson County District Court No. 23JV30049 Honorable Lindsay L. VanGilder, Judge

The People of the State of Colorado,

Appellee,

In the Interest of E.N., a Child,

and Concerning R.N.,

Appellant.

JUDGMENT AFFIRMED

Division III Opinion by JUDGE MEIRINK Dunn and Tow, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 1, 2025

Kimberly S. Sorrells, County Attorney, Claire M. Czajkowski, Assistant County Attorney, Golden, Colorado, for Appellee

Eric Truhe, Guardian Ad Litem

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

the judgment terminating her parent-child legal relationship with

E.N. (the child). Mother contends that the juvenile court erred by

finding that (1) the Jefferson County Division of Children, Youth,

and Families (the Division) provided reasonable efforts to

rehabilitate her; and (2) she could not become fit within a

reasonable time. We disagree and affirm.

I. Background

¶2 The Division received a referral in March 2023 with concerns

about the then-newborn child based on mother’s report that she

was living in a home where methamphetamine was manufactured.

The referral reported that mother was experiencing sudden changes

in mood and was escalated, hostile, and violent towards hospital

staff.

¶3 After receiving additional information that the child’s umbilical

cord tissue tested positive for methamphetamine, the Division filed

a petition in dependency and neglect. The Division alleged concerns

for mother’s mental health, substance dependence, and an unsafe

living environment.

1 ¶4 The juvenile court adjudicated the child dependent and

neglected. Mother’s court-adopted treatment plan consisted of two

objectives requiring her to complete substance abuse and mental

health intakes or assessments and follow the recommendations.

The court also adopted a parenting plan requiring mother to attend

supervised family time with the child.

¶5 The Division later moved to terminate both mother’s rights. In

October 2024, nineteen months after the petition was filed, the

juvenile court terminated mother’s parental rights following a

contested hearing.1

II. Reasonable Efforts

¶6 Mother contends that the juvenile court erred by finding that

the Division made reasonable efforts because it did not adequately

comply with the Americans with Disabilities Act (ADA). However,

mother did not ask the juvenile court to make findings under the

ADA, and, reviewing the court’s reasonable efforts findings, we

discern no error.

1 The juvenile court found that father abandoned the child and

terminated his parental rights. Father did not participate in the case and does not participate in this appeal.

2 A. Standard of Review and Applicable Law

¶7 Whether a department satisfied its obligation to make

reasonable efforts to reunify the family is a mixed question of fact

and law. People in Interest of A.S.L., 2022 COA 146, ¶ 8. We review

the juvenile court’s factual findings related to reasonable efforts for

clear error but review de novo the court’s legal determination, based

on those findings, as to whether the department satisfied its

reasonable efforts obligation. Id.

¶8 Before the juvenile court may terminate parental rights under

section 19-3-604(1)(c), C.R.S. 2024, the state must make

reasonable efforts to rehabilitate the parent and reunite the family.

§§ 19-1-103(114), 19-3-100.5(1), 19-3-208, 19-3-604(2)(h), C.R.S.

2024. Reasonable efforts means the “exercise of diligence and care”

for a child who is in out-of-home placement, and the reasonable

efforts standard is satisfied when services are provided in

accordance with section 19-3-208.

¶9 The services provided under section 19-3-208 generally must

comply with the ADA and Section 504 of the Rehabilitation Act of

1973, their related amendments, and their implementing

regulations. § 19-3-208(2)(g); People in Interest of S.K., 2019 COA

3 36, ¶¶ 22, 25, 34; see 42 U.S.C. § 12102 (defining “disability” under

the ADA).

¶ 10 Under the ADA no “qualified individual with a disability” shall,

by reason of such disability, be excluded from participation in or be

denied the benefits of the services, programs, or activities of a

public entity, or be subjected to discrimination by any such entity.2

People in Interest of C.Z., 2015 COA 87, ¶ 11.

¶ 11 As relevant here, a disability under the ADA requires more

than a diagnosis of a mental or physical impairment. 29 C.F.R.

1630.2(j)(ii) (2024)(“not every impairment will constitute a disability

within the meaning of this section”). Rather, when the impairment

is the basis of the disability, the ADA requires a showing that the

2 A “qualified individual with a disability” is an

individual with a disability who, with or without reasonable modifications to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity.

42 U.S.C. § 12131(2).

4 impairment “substantially limits one or more major life activities” of

the individual. 42 U.S.C. § 12102(2); See Hughes v. Colo. Dep’t of

Corr., 594 F. Supp. 2d 1226, 1239-40 (D. Colo. 2009); RHJ Med.

Ctr, Inc. v. City of DuBois, 754 F. Supp. 2d 723, 750 (W.D. Pa. 2010)

(noting that the court conducts “an individualized, fact-intensive

inquiry” to determine whether an individual has a disability).

¶ 12 When a parent is found to be a qualified individual with a

disability, the juvenile court must then consider whether the

Department made reasonable accommodations for a parent's

disability when determining whether it made reasonable efforts.

S.K., ¶ 34.

¶ 13 With this legal framework in mind, we turn to the

circumstances of mother’s claim.

B. Additional Background

1. Mother’s Representations About Her Visual Impairment

¶ 14 At the disposition hearing in May 2023, mother asserted that

she lived with a visual impairment and received Social Security

5 Disability Insurance (SSDI).3 Mother’s representation changed over

time, and it was unclear whether her SSDI payments were related

to her vision impairment. Throughout the case, neither the Division

nor the juvenile court could confirm if mother received SSDI or

what, if any, disability determination had been made by the Social

Security Administration.4

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Related

Hughes v. Colorado Department of Corrections
594 F. Supp. 2d 1226 (D. Colorado, 2009)
RHJ Medical Center, Inc. v. City of DuBois
754 F. Supp. 2d 723 (W.D. Pennsylvania, 2010)
v. Colorado Cab Company LLC
2019 COA 3 (Colorado Court of Appeals, 2019)
People ex rel. C.Z.
2015 COA 87 (Colorado Court of Appeals, 2015)

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