Peo in Interest of E.Q

2020 COA 118
CourtColorado Court of Appeals
DecidedAugust 3, 2020
Docket20CA0089
StatusPublished
Cited by513 cases

This text of 2020 COA 118 (Peo in Interest of E.Q) 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 E.Q, 2020 COA 118 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY July 30, 2020

2020COA118

No. 20CA0089, Peo in Interest of E.Q. — Children’s Code — Juvenile Court — Dependency and Neglect — Allocation of Parental Responsibilities, Parenting Time, Child Support — Child Support Guidelines

In this dependency and neglect proceeding, a division of the

court of appeals considers two matters of first impression in

Colorado. The division first holds that when a juvenile court orders

child support under section 19-1-104(6), C.R.S. 2019, it must

comply with article 6 of the Children’s Code, specifically section 19-

6-106, C.R.S. 2019, and use the child support guidelines set forth

in section 14-10-115, C.R.S. 2019, to compute child support. The

division further holds that, consistent with the Social Security Act,

the juvenile court may not order one parent to designate the other

parent as the representative payee of his or her social security disability benefits. Accordingly, the child support judgment is

reversed, and the case is remanded for further proceedings. COLORADO COURT OF APPEALS 2020COA118

Court of Appeals No. 20CA0089 Prowers County District Court No. 19JV22 Honorable Stanley A. Brinkley, Judge

The People of the State of Colorado,

Appellee,

In the Interest of E.Q. and J.Q., Children,

and Concerning R.Q.,

Appellant,

and

J.Q.,

Appellee.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division IV Opinion by JUDGE FREYRE Terry and Lipinsky, JJ., concur

Announced July 30, 2020

Scranton Specht Associates P.C., Darla Scranton Specht, Lamar, Colorado, for Appellee

Kim R. Verhoeff, Guardian Ad Litem

Debra W. Dodd, Office of Respondent Parents’ Counsel, Berthoud, Colorado, for Appellant

Roy Wallis, Office of Respondent Parents’ Counsel, Mesa, Arizona, for Appellee ¶1 In this dependency and neglect proceeding, R.Q. (father)

appeals the juvenile court’s judgment ordering child support in

conjunction with granting a stipulation to allocate parental

responsibilities for the children to J.Q. (mother). Although father

agrees that he has a duty to support the children, he challenges the

provisions in the order requiring him to release his social security

disability insurance (SSDI) benefits to mother and designate her as

the payee for his benefits.

¶2 To resolve father’s appeal, we must answer two questions that

have not yet been answered by Colorado’s appellate courts. First,

what standard or criteria should the juvenile court apply when

ordering child support in a dependency and neglect proceeding

under section 19-1-104(6), C.R.S. 2019? We hold that a court must

follow the provisions for determining child support set forth in

section 19-6-106, C.R.S. 2019, which, in turn, requires compliance

with the child support guidelines in section 14-10-115, C.R.S.

2019. Because the court’s order failed to address the factors set

forth in the child support guidelines, we reverse the child support

judgment and remand the case for further proceedings.

1 ¶3 Second, may a juvenile court order one parent to designate the

other parent as the representative payee of his or her SSDI benefits

as part of a child support order? We hold that it may not because

federal law does not permit a juvenile court to determine the

designated payee of a parent’s SSDI benefits. Therefore, we reverse

the court’s child support judgment on this basis as well.1

I. Factual Background

¶4 In April 2019, the Prowers County Department of Human

Services (Department) filed a dependency and neglect petition

concerning sixteen-year-old E.Q. and thirteen-year-old J.Q. The

petition alleged that father had sexually abused E.Q. and had

admitted to some of the abuse when mother confronted him. The

juvenile court placed the children in mother’s custody under the

protective supervision of the Department. The following month,

father was arrested and charged criminally. He remained

incarcerated throughout the remainder of the case.

¶5 The juvenile court adjudicated the children dependent and

neglected based on the parties’ stipulation. It adopted a treatment

1Those portions of the judgment not challenged on appeal remain undisturbed.

2 plan for father. In October 2019, mother initiated a separate

proceeding to dissolve her marriage to father.

¶6 Two months later, the parties reached a stipulation concerning

parental responsibilities for the children. As pertinent here, the

stipulation provided that (1) mother would be the children’s

custodian and have sole decision-making responsibilities; and (2)

child support would be determined by the domestic relations court.

Mother also filed a motion asking the juvenile court to order father

to release his prior three months of SSDI benefits to her. Father

filed a written objection to this motion.

¶7 After hearing further argument and offers of proof from the

parties, the juvenile court issued an order adopting the parties’

stipulation and addressing mother’s motion. Finding that it had

jurisdiction to consider child support in a dependency and neglect

proceeding under section 19-1-104(6), the court ordered father to

turn over his previous three months of SSDI benefits to mother and

to restore mother as the payee of his benefits until further order of

the court. It then certified the order into the parties’ domestic

relations proceeding.

3 II. Jurisdiction and Terms of the Stipulation

¶8 Father contends that the juvenile court lacked jurisdiction to

issue the child support order addressing his SSDI benefits because

it had already ended the case when it approved the parties’

stipulation. He reasons that, by accepting the parties’ stipulation to

defer child support to the domestic court, the court was precluded

from entering any child support orders. We reject father’s

jurisdictional argument but conclude that the court must

reconsider the conflicting provisions regarding child support in the

order.

A. Standard of Review and Law

¶9 Whether a juvenile court has subject matter jurisdiction is a

question of law that we review de novo. In re Petition of E.R.S., 2019

COA 40, ¶ 23.

¶ 10 Subject matter jurisdiction concerns a court’s authority to

decide a particular matter. Id. at ¶ 24; see also In re Support of

E.K., 2013 COA 99, ¶ 8. Dependency and neglect proceedings are

governed by the Children’s Code. L.A.G. v. People in Interest of

A.A.G., 912 P.2d 1385, 1389 (Colo. 1996). The Children’s Code

grants a juvenile court exclusive jurisdiction over any child who is

4 dependent and neglected. § 19-1-104(1)(b). It also expressly

authorizes a juvenile court to enter an order allocating parental

responsibilities and addressing parenting time and child support

matters when it maintains jurisdiction in a case involving a child

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2020 COA 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-eq-coloctapp-2020.