Peo in Interest of ERP

CourtColorado Court of Appeals
DecidedJune 11, 2026
Docket25CA2256
StatusUnpublished

This text of Peo in Interest of ERP (Peo in Interest of ERP) 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 ERP, (Colo. Ct. App. 2026).

Opinion

25CA2256 Peo in Interest of ERP 06-11-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA2256 Delta County District Court No. 23JV30005 Honorable J. Steven Patrick, Judge

The People of the State of Colorado,

Appellee,

In the Interest of E.R.P. and R.P., Children,

and Concerning O.R.K. and J.J.P.,

Appellants.

JUDGMENT AFFIRMED

Division VI Opinion by JUDGE GOMEZ Grove and Moultrie, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced June 11, 2026

John Baier, County Attorney, Jodie L. Behrmann, Assistant County Attorney, Delta, Colorado, for Appellee

Robert G. Tweedell, Guardian Ad Litem

Just Law Group, LLC, John F. Poor, Denver, Colorado, for Appellant O.R.K.

The Morgan Law Office, Kristofr P. Morgan, Colorado Springs, Colorado, for Appellant J.J.P. ¶1 In this dependency or neglect proceeding, J.J.P. (father) and

O.R.K. (mother) appeal the judgment terminating their parent-child

legal relationships with E.R.P. and R.P. (the children). We affirm.

I. Background

¶2 In February 2023, the Delta County Department of Human

Services (the Department) received a referral reporting concerns

about mother’s substance use. A caseworker met with mother, who

admitted that she used methamphetamine while caring for the

children, and observed father to be highly intoxicated. As a result,

the Department filed a petition in dependency and neglect.

¶3 Following the parents’ no-fault admissions, the juvenile court

adjudicated the children dependent and neglected. The court then

adopted treatment plans for the parents requiring them to

(1) cooperate with the Department; (2) complete substance abuse

and mental health evaluations and follow all recommendations;

(3) maintain sobriety; (4) submit to drug testing as requested by the

Department; (5) demonstrate the ability to provide for the children’s

financial, physical, and mental health, as well as their

developmental needs; and (6) maintain a safe, stable, and suitable

residence for the children. Nearly two years later, the Department

1 moved to terminate the parents’ legal relationships with the

children. In November 2025, following a two-day hearing, the

juvenile court granted the motion and terminated father’s and

mother’s parental rights.

II. Termination Criteria and Standard of Review

¶4 A juvenile court may terminate parental rights if it finds, by

clear and convincing evidence, that (1) the children were

adjudicated dependent or neglected; (2) the parent has not complied

with an appropriate, court-approved treatment plan or the plan has

not been successful; (3) the parent is unfit; and (4) the parent’s

conduct or condition is unlikely to change within a reasonable time.

§ 19-3-604(1)(c), C.R.S. 2025.

¶5 Where, as here, the children are under the age of six at the

time the petition is filed, the court must also consider the expedited

permanency planning (EPP) provisions, which require the court to

place the children in a permanent home as expeditiously as

possible. §§ 19-1-102(1.6), 19-1-123, 19-3-702(5)(c), C.R.S. 2025.

¶6 Whether the juvenile court properly terminated parental rights

is a mixed question of fact and law. People in Interest of A.M. v.

T.M., 2021 CO 14, ¶ 15; see also People in Interest of A.S.L., 2022

2 COA 146, ¶ 8 (applying the same standard of review to a

determination of whether a department of human services satisfied

its obligation to make reasonable efforts). We review the court’s

factual findings for clear error, but we review de novo its legal

conclusions based on those facts. People in Interest of S.R.N.J-S.,

2020 COA 12, ¶ 10. The credibility of witnesses; the sufficiency,

probative value, and weight of the evidence; and the inferences and

conclusions drawn from the evidence are all matters within the

discretion of the juvenile court. A.M., ¶ 15.

III. Father’s Contentions

A. Adequacy of Findings

¶7 Father contends that the juvenile court’s findings were

inadequate to support the termination judgment because the court

didn’t expressly find that (1) he was unfit; (2) his conduct or

condition was unlikely to change within a reasonable time; and

3 (3) termination was in the children’s best interests. We discern no

reversible error.1

1. Preservation

¶8 The Department and the children’s guardian ad litem (GAL)

urge us not to address this issue because father didn’t move for

post-trial relief to preserve it. But an appellant is not required to

file a post-trial motion with the juvenile court, and failing to do so

doesn’t preclude the appellant from raising an issue on appeal. See

C.R.C.P. 59(b). Moreover, a party need not object to a court’s

findings to preserve a challenge to those findings. See In re

Marriage of Crouch, 2021 COA 3, ¶ 17; C.R.C.P. 52. Accordingly, we

consider father’s assertion of error regarding the adequacy of the

juvenile court’s findings.

2. Applicable Law

¶9 The findings supporting a termination judgment are adequate

if they conform to the criteria in section 19-3-604. People in Interest

1 To the extent that father asserts the juvenile court’s findings were

insufficient to support the termination of mother’s parental rights, we reject the assertion because father lacks standing to challenge the termination of mother’s parental rights. See People in Interest of J.M.B., 60 P.3d 790, 792 (Colo. App. 2002) (one parent doesn’t have standing to raise issues regarding another parent’s rights).

4 of A.G.-G., 899 P.2d 319, 323 (Colo. App. 1995). The findings must

“adequately address and resolve each specific requirement for

termination.” People in Interest of M.C.C., 641 P.2d 306, 308 (Colo.

App. 1982). We will set aside a judgment for inadequate findings

only when the findings don’t conform to the statutory criteria and

don’t allow us to determine the basis for the court’s judgment. See

People in Interest of J.M.B., 60 P.3d 790, 794 (Colo. App. 2002).

¶ 10 “When an order is ambiguous, the reviewing court is charged

with the task of determining what the trial court intended in issuing

the order. In so doing, the court may refer to the entire record and

to the circumstances surrounding the order.” People in Interest of

D.C-M.S., 111 P.3d 559, 562 (Colo. App. 2005).

3. Analysis

¶ 11 We agree with father that the juvenile court’s findings

regarding the section 19-3-604(1)(c) termination criteria could have

been more detailed. But the court’s findings sufficiently allow us to

determine the basis for its termination judgment.

a. Fitness

¶ 12 The juvenile court found that father didn’t meet his treatment

plan objectives, and that, despite the Department’s reasonable

5 efforts, his treatment plan was unsuccessful. See § 19-3-604(2)(h)

(when determining a parent’s fitness, a juvenile court must consider

“[r]easonable efforts by child-caring agencies which have been

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Peo in Interest of ERP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-erp-coloctapp-2026.