Peo in Interest of J-TM

CourtColorado Court of Appeals
DecidedMarch 12, 2026
Docket25CA1281
StatusUnpublished

This text of Peo in Interest of J-TM (Peo in Interest of J-TM) 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 J-TM, (Colo. Ct. App. 2026).

Opinion

25CA1281 Peo in Interest of J-TM 03-12-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA1281 Weld County District Court No. 22JV29 Honorable Troy Hause, Judge

The People of the State of Colorado,

Appellee,

In the Interest of J-T.M., a Child,

and Concerning E.P.,

Appellant.

JUDGMENT AFFIRMED

Division IV Opinion by JUDGE SCHUTZ Freyre and Brown, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced March 12, 2026

Bruce T. Barker, County Attorney, David S. Anderson, Assistant County Attorney, Greeley, Colorado, for Appellee

Josi McCauley, Guardian Ad Litem

Just Law Group, LLC, John F. Poor, Denver, Colorado, for Appellant ¶1 In this dependency or neglect proceeding, E.P. (mother)

appeals the judgment terminating her parent-child legal

relationship with J-T.M. (the child). We affirm.

I. Background

¶2 The Weld County Department of Human Services (Department)

initiated an action in dependency or neglect based on concerns

related to mother’s financial and housing instability, mental health,

and medical neglect of the child. The juvenile court adjudicated the

child dependent or neglected and adopted a treatment plan for

mother.

¶3 Mother appealed, and a division of this court reversed the

adjudication judgment based on the juvenile court’s failure to

properly determine whether it had jurisdiction over the matter.

People in Interest of J-T.M., (Colo. App. No. 22CA2242, Sep. 7, 2023)

(not published pursuant to C.A.R. 35(e)). After a remand, the

juvenile court determined it had jurisdiction, reinstated the

adjudication, and readopted mother’s treatment plan. Mother

appealed the reinstated adjudication, which was upheld on appeal

by another division of this court in People in Interest of J-T.M., (Colo.

1 App. No. 24CA150, Sep. 12, 2024) (not published pursuant to

C.A.R. 35(e)).

¶4 Later, the Department moved to terminate mother’s parental

rights. Following an evidentiary hearing, the juvenile court granted

the termination motion.

II. Criteria for Termination and Standard of Review

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

clear and convincing evidence, that (1) the child has been

adjudicated dependent or neglected; (2) the parent hasn’t

reasonably complied with an appropriate treatment plan or the plan

hasn’t been successful in rendering the parent fit; (3) the parent

remains 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.

¶6 When, as here, a child is under six years old at the time a

petition in dependency or neglect is filed, the juvenile court must

place the child 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; see People

in Interest of S.Z.S., 2022 COA 133, ¶ 25.

¶7 Whether a juvenile court properly terminated parental rights

presents a mixed question of law and fact because it involves

2 application of the termination statute to evidentiary facts. People in

Interest of L.M., 2018 COA 57M, ¶ 17. We review the court’s factual

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

including whether the department satisfied its reasonable efforts

obligation. People in Interest of S.R.N.J-S., 2020 COA 12, ¶ 10;

People in Interest of A.S.L., 2022 COA 146, ¶ 8. The credibility of

the witnesses; sufficiency, probative value, and weight of the

evidence; and the inferences and conclusions to be drawn therefrom

are within the discretion of the juvenile court. People in Interest of

A.M. v. T.M., 2021 CO 14, ¶ 15.

III. Reasonable Efforts

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

the Department fulfilled its duty to provide reasonable efforts.

Specifically, she asserts that (1) her in-person family time was

erroneously suspended; (2) the length of the suspension was

unreasonable; and (3) in-person family time should have been held

in Colorado. We consider, and reject, each contention below.

A. Preservation

¶9 The guardian ad litem argues that, although mother preserved

a reasonable efforts argument generally, she did not preserve the

3 specific arguments she now asserts on appeal. We need not decide

this issue because, even if we assume mother preserved her claim,

we discern no reversible error.

B. Applicable Law

¶ 10 To determine whether a parent is unfit, the juvenile court

must consider whether the department of human services made

reasonable efforts to rehabilitate the parent and reunite the family.

See §§ 19-3-100.5(1), 19-3-604(2)(h), C.R.S. 2025; People in Interest

of S.N-V., 300 P.3d 911, 915 (Colo. App. 2011). 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

if appropriate services are provided to a parent in accordance with

section 19-3-208, C.R.S. 2025. § 19-1-103(114), C.R.S. 2025.

Under that statute, family time is among the services that “must be

available and provided” as determined necessary and appropriate

by individual case plans. § 19-3-208(1), (2)(b)(IV); People in Interest

of B.C., 122 P.3d 1067, 1070 (Colo. App. 2005).

¶ 11 In determining whether family time services are necessary and

appropriate, the health and safety of the child are paramount. See

B.C., 122 P.3d at 1070. Family time services should further the

4 purposes of the Children’s Code, including the preservation of

familial ties whenever possible. § 19-1-102(1)(b). However, family

time services may be denied or limited if the court finds “that

visitation with the parent would be detrimental to the health and

safety of the child.” People in Interest of E.S., 2021 COA 79, ¶ 23.

¶ 12 To evaluate whether a department made reasonable efforts,

the juvenile court should consider whether the services provided

were appropriate to support the parent’s treatment plan. S.N-V.,

300 P.3d at 915. The parent is ultimately responsible for using the

services provided to obtain the assistance needed to comply with

the treatment plan. People in Interest of J.C.R., 259 P.3d 1279,

1285 (Colo. App. 2011). The court may therefore consider a

parent’s unwillingness to participate in services when determining

whether a department made reasonable efforts. See People in

Interest of A.V., 2012 COA 210, ¶ 12.

C. Additional Background

¶ 13 Following the child’s removal from the home, the juvenile court

ordered regular weekly supervised family time. To that end, the

Department set up in-person supervised visits, and mother

attended regularly.

5 ¶ 14 During family time, mother routinely inspected the child’s

body (including the child’s genitals) and would show pictures of the

child’s face and body to professionals involved in the case, asserting

there were visible injuries on the child. The professionals did not

see the injuries mother purported to see.

¶ 15 Roughly four months after supervised family time began,

mother again alleged there were injuries on the child and that he

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Related

in Interest of S.R.N.J-S
2020 COA 12 (Colorado Court of Appeals, 2020)
in Interest of A.M
2021 CO 14 (Supreme Court of Colorado, 2021)
in Int. of B.H
2021 CO 39 (Supreme Court of Colorado, 2021)
in Interest of E.S
2021 COA 79 (Colorado Court of Appeals, 2021)
People ex rel. B.C.
122 P.3d 1067 (Colorado Court of Appeals, 2005)
People ex rel. N.D.V.
224 P.3d 410 (Colorado Court of Appeals, 2009)
People ex rel. A.V.
2012 COA 210 (Colorado Court of Appeals, 2012)

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