Peo in Interest of JL

Colorado Court of Appeals·Decided July 30, 2026·No. 26CA0117·Unpublished

Opinion

26CA0117 Peo in Interest of JL 07-30-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 26CA0117 Douglas County District Court No. 23JV30057 Honorable Ryan J. Stuart, Judge

The People of the State of Colorado,

Appellee,

In the Interest of Jac.L. and Jax.L., Children,

and Concerning B.B. a/k/a B.L.,

Appellant.

JUDGMENT AFFIRMED

Division V Opinion by JUDGE SCHUTZ Lipinsky and Yun, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced July 30, 2026

Jeffrey A. Garcia, County Attorney, Erinn Walz, Assistant County Attorney, Castle Rock, Colorado, for Appellee

Debra W. Dodd, Guardian Ad Litem

The Morgan Law Office, Kristofr P. Morgan, Colorado Springs, Colorado, for Appellant ¶1 In this dependency and neglect proceeding, B.B. a/k/a B.L.

(mother) appeals the judgment terminating her parent-child legal

relationships with Jac.L. and Jax.L. (the children). We affirm.

I. Background

¶2 In May 2023, the Douglas County Department of Human

Services filed a petition in dependency and neglect based on

concerns about, among other things, mother’s substance use. The

juvenile court adjudicated the children dependent or neglected and

adopted a treatment plan for mother.

¶3 The children resided in several placements during the

pendency of this case. Shortly after the case was opened, the court

removed the children from the family home. Following two

consecutive, brief foster placements, the children were returned

home to mother on a trial basis. Ten months later, the Department

received a report alleging that mother drove under the influence

with the children’s half-sibling (who is not involved in this appeal).

The court then ordered that the children be placed in foster care.

Later, the court ordered an Interstate Compact on Placement of

Children (ICPC) home study of the children’s maternal

grandmother’s home in New York. The ICPC home study was

1 approved, and the court placed the children with maternal

grandmother, where they remained for the duration of the case.

¶4 After holding a hearing on the Department’s termination

motion in December 2025, the court terminated mother’s

parent-child legal relationships with the children.

II. Less Drastic Alternatives

¶5 Mother contends that the juvenile court erred by determining

that there was no viable less drastic alternative to termination of

her parental rights. She asserts that the children’s best interests

would have been served through an allocation of parental

responsibilities (APR) to maternal grandmother instead. We are not

persuaded.

A. Legal Framework and Standard of Review

¶6 A juvenile court may terminate a parent’s parental rights if it

finds, by clear and convincing evidence, that (1) the child was

adjudicated dependent and neglected; (2) the parent has not

reasonably 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 in a

reasonable time. § 19-3-604(1)(c), C.R.S. 2025.

2 ¶7 Before terminating parental rights under section

19-3-604(1)(c), the court must also consider and eliminate less

drastic alternatives. People in Interest of L.M., 2018 COA 57M, ¶ 24.

In considering less drastic alternatives, a court must give primary

consideration to the child’s physical, mental, and emotional

conditions and needs. People in Interest of Z.M., 2020 COA 3M,

¶ 29; see § 19-3-604(3). The court may also consider, among other

things, the parent’s fitness, see L.M., ¶ 27, and whether an APR

would adequately meet the child’s need for permanence and other

needs, see People in Interest of T.E.M., 124 P.3d 905, 910 (Colo.

App. 2005).

¶8 For a less drastic alternative to be viable, it must do more than

adequately meet the child’s needs; rather, it must be in the child’s

best interests. People in Interest of A.M. v. T.M., 2021 CO 14, ¶ 27.

¶9 “We review a juvenile court’s less drastic alternatives findings

for clear error.” People in Interest of E.W., 2022 COA 12, ¶ 34.

Thus, when a court considers less drastic alternatives because it

finds that termination is in the child’s best interests, we are bound

3 to affirm the decision so long as the record supports its findings.1

People in Interest of B.H., 2021 CO 39, ¶ 80.

B. Analysis

¶ 10 The juvenile court determined that an APR would not achieve

the permanency that the children “deserve[d]” and that there was

not a less drastic alternative that would serve their best interests.

See T.E.M., 124 P.3d at 910. In doing so, the court found that

mother had not seen the children in months, had not improved her

relationship with them, and was unlikely to achieve sobriety in

sufficient time to be able to parent them. See L.M., ¶ 27. The court

also found that the children’s needs were being met by maternal

grandmother, who wished to adopt them. See Z.M., ¶ 31

(recognizing that the juvenile court may consider whether the

placement favors adoption rather than an APR).

1 In People in Interest of H.L.B., 2025 COA 86, cert. granted,

25SC721, 2026 WL 353234 (Colo. Feb. 2, 2026), Judge Welling filed a special concurrence suggesting that the supreme court may wish to consider whether it is more appropriate to review a trial court’s factual findings regarding a less drastic alternative for clear error, but review the court’s ultimate conclusion of whether a less drastic alternative is in the children’s best interest under the abuse of discretion standard. See id. at ¶ 40 (Welling, J., specially concurring).

4 ¶ 11 The record supports the court’s findings and shows that

maintaining sobriety was a longstanding struggle for mother.

Mother’s drug and alcohol use was an issue in a prior dependency

and neglect case. The caseworker testified that mother had not

demonstrated sobriety during this case. She explained her concern

that mother was using substances based on mother’s behavior

throughout the case and various reports that the caseworker had

received.

¶ 12 The record also shows that mother did not have contact with

the children for extended periods during the pendency of the case.2

One of those stretches spanned over two months and directly

preceded the termination hearing. Mother did not consistently or

timely attend her therapeutic family time and sometimes returned

2 The caseworker testified that there were periods during the case in

which she was unable to reach mother or the children’s father, J.L. (father). With respect to father, the caseworker described, more precisely, that he communicated only “[v]ery sporadic[ally]” with the Department and “never engaged” in rehabilitative services during the case, outside of therapeutic family time. Domestic violence on father’s part was one of the reasons the Department opened the case, and father never completed a domestic violence offender evaluation or treatment. The juvenile court also terminated father’s parent-child legal relationships with the children. Father does not appeal that ruling.

5 to her car during sessions. The family time supervisor testified that

supervision remained at this level because, (1) “on the whole,”

mother did not mitigate the Department’s various concerns about

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

Peo in Interest of JL, (Colo. Ct. App. 2026).

Peo in Interest of JL (Peo in Interest of JL) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In re Marriage of Kann
2017 COA 94 (Colorado Court of Appeals, 2017)
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)
People in Interest of H.L.B.
2025 COA 86 (Colorado Court of Appeals, 2025)