Peo in Interest of JLC

CourtColorado Court of Appeals
DecidedFebruary 6, 2025
Docket24CA0935
StatusUnpublished

This text of Peo in Interest of JLC (Peo in Interest of JLC) 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 JLC, (Colo. Ct. App. 2025).

Opinion

24CA0935 Peo in Interest of JLC 02-06-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0935 Larimer County District Court No. 23JV30009 Honorable Gregory M. Lammons, Judge

The People of the State of Colorado,

Appellee,

In the Interest of J.L.C., a Child,

and Concerning J.C., III and J.C.,

Appellants.

JUDGMENT AFFIRMED

Division VII Opinion by JUDGE MOULTRIE Lipinsky and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced February 6, 2025

William G. Ressue, County Attorney, Arthur J. Spicciati, Assistant County Attorney, Fort Collins, Colorado, for Appellee

Josi McCauley, Guardian Ad Litem

Andrew A. Gargano, Office of Respondent Parents’ Counsel, Denver, Colorado, for Appellant J.C., III

Just Law Group, LLC, John F. Poor, Denver, Colorado, for Appellant J.C. ¶1 J.C., III (father) and J.C. (mother) appeal the judgment

terminating their parent-child legal relationships with J.L.C. (the

child). We affirm.1

I. Background

¶2 In January 2023, the Larimer County Department of Human

Services (Department) filed a petition in dependency and neglect

due to concerns that the child experienced a pulmonary

hemorrhage at birth and needed to be resuscitated, and that

mother admitted to daily fentanyl use during her pregnancy. The

child entered a neonatal intensive care unit, where she received

intravenous fentanyl to combat withdrawal symptoms. The

Department also had concerns about father’s substance use.

¶3 The parents failed to appear at their respective adjudication

trials, and the juvenile court adjudicated the child dependent and

1 The Larimer County Department of Human Services’ answer brief

purports to incorporate by reference the guardian ad litem’s answer brief “in its entirety,” except for father’s argument that the juvenile court erred by denying his request for a continuance. Similarly, mother’s counsel filed a “Notice of Joinder in Father’s First Issue on Appeal Relating to ICWA Compliance.” This practice violates C.A.R. 28(h). See Frisco Lot 3 LLC v. Giberson Ltd. P’ship, LLLP, 2024 COA 125, ¶¶ 17-21. The parties are placed on notice that this court may sanction future violations of this rule by striking a portion or all of a party’s brief or imposing other sanctions, as appropriate.

1 neglected following bench trials. The court adopted treatment plans

for the parents that required them to (1) address their substance

abuse issues; (2) address their mental health concerns; (3) provide a

safe and stable home and meet the child’s needs; (4) communicate

with the Department and professionals; (5) attend family time; and

(6) refrain from criminal activity.

¶4 In November 2023, the Department moved to terminate the

parents’ parental rights. The juvenile court held an evidentiary

hearing in April 2024. Following the hearing, the court entered a

written ruling that granted the Department’s motion and terminated

the parent-child legal relationships between the parents and the

child.

II. Indian Child Welfare Act

¶5 Father first asserts that the juvenile court did not comply with

the provisions of the Indian Child Welfare Act (ICWA) of 1978, 25

U.S.C. §§ 1901-1963, and Colorado’s ICWA statute, § 19-1-126,

C.R.S. 2024. Specifically, he contends that the court erred by

failing to make proper inquiries and concluding that the

Department had exercised due diligence under section 19-1-126(3).

We disagree.

2 A. Applicable Law and Standard of Review

¶6 For ICWA to apply in a dependency and neglect proceeding,

the case must involve an Indian child. See People in Interest of

A.G.-G., 899 P.2d 319, 321 (Colo. App. 1995); see also 25 U.S.C.

§ 1903(4) (defining “Indian child” as “any unmarried person who is

under age eighteen” and (1) “a member of an Indian tribe,” or

(2) “eligible for membership in an Indian tribe” and “the biological

child of a member of an Indian tribe”). We review de novo whether

the juvenile court complied with ICWA. People in Interest of T.M.W.,

208 P.3d 272, 274 (Colo. App. 2009).

¶7 To ascertain whether the case involves an Indian child, a

juvenile court must inquire of the parties at the commencement of

the proceeding whether they know or have reason to know that the

child is an Indian child. § 19-1-126(1)(a)(I)(A). The court must

make a new inquiry if a proceeding to terminate parental rights is

initiated during a dependency and neglect case. C.R. ICWA P. 3(a),

(c).

¶8 A mere assertion of Indian heritage, without more, is

insufficient to give the juvenile court reason to know that the child

is an Indian child. People in Interest of E.A.M. v. D.R.M., 2022 CO

3 42, ¶ 56. If the court does not have reason to know but has

information that “the child may have Indian heritage,” then the

court must direct the department to “exercise due diligence in

gathering additional information that would assist the court in

determining whether there is reason to know that the child is an

Indian child.” § 19-1-126(3); see also H.J.B. v. People in Interest of

A-J.A.B., 2023 CO 48, ¶ 5. Due diligence “requires the department

to earnestly endeavor to investigate the basis for the parent or other

participant’s assertion that the child may be an Indian child.”

H.J.B., ¶ 57.

¶9 Whether the department satisfied its due diligence obligation

is left to the court’s sound discretion. Id. at ¶ 58.

B. Analysis

¶ 10 In March 2023, the Department sent ICWA notices to the eight

federally recognized Apache tribes. The Department attached an

affidavit from the caseworker, which stated that maternal

grandmother had told the Department that “the family belong[ed] to

the Chiricahua Apache [T]ribe in Colorado.” However, maternal

grandmother did not believe that anyone in the family was a

registered member of a tribe. The Chiricahua Apache Tribe is not a

4 federally recognized tribe, but the parties agree that the Chiricahua

Apaches’ ancestors were members of three federally recognized

tribes: Fort Sill Apache Tribe, Mescalero Apache Tribe, and San

Carlos Apache Tribe. See People in Interest of L.L., 2017 COA 38,

¶ 36 (noting that “ICWA applies only if the Tribe is a federally

recognized Indian Tribe”), overruled on other grounds by E.A.M.,

¶ 56 n.10.

¶ 11 The record indicates that all eight federally recognized Apache

tribes received the Department’s notice. A few of the tribes

indicated that the child was not a member of, or eligible for

membership in, the tribe. However, the Mescalero Apache Tribe

responded that mother or father (or possibly both) was a member of

the Tribe. Yet, the Tribe indicated that the child was not eligible for

membership in the Tribe. As pertinent to this appeal, the Fort Sill

Apache Tribe and San Carlos Apache Tribe did not respond to the

Department.

¶ 12 At a setting conference in early February 2024, the juvenile

court noted that it had seen the letter from the Mescalero Apache

Tribe stating that the child was not eligible. However, the court

further noted that, in the motion to terminate, the Department had

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