Peo in Interest of MB

CourtColorado Court of Appeals
DecidedMay 1, 2025
Docket24CA0102
StatusUnpublished

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

Opinion

24CA0102 Peo in Interest of MB 05-01-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0102 Arapahoe County District Court No. 21JV709 Honorable Bonnie H. Mclean, Judge

The People of the State of Colorado,

Appellee,

In the Interest of M.B. and A.B., Children,

and Concerning L.B.,

Appellant.

JUDGMENT AFFIRMED

Division VI Opinion by JUDGE WELLING Kuhn and Schutz, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 1, 2025

Ron Carl, County Attorney, Sarah Simchowitz, Assistant County Attorney, Aurora, Colorado, for Appellee

Sheena Knight, Counsel for Youth, Brighton, Colorado, for M.B. and A.B.

Gregory Lansky, Office of Respondent Parents’ Counsel, Aurora, Colorado, for Appellant ¶1 In this dependency and neglect action, L.B. (father) appeals

the judgment terminating his parent-child legal relationships with

M.B. and A.B. (the youths). We affirm.

I. Background

¶2 The Arapahoe County Department of Human Services filed a

petition in dependency and neglect alleging that K.S. (mother) left

the youths with the maternal grandmother in Colorado after fleeing

the state of Alabama to avoid ongoing involvement with child

protective services there. The Department alleged concerns about

mother’s substance dependence and ability to provide for the

emotional and physical needs of the youths, who were eleven and

thirteen at that time. The Department also alleged that the

maternal grandmother was estranged from mother, didn’t have a

relationship with either youth, and couldn’t provide ongoing

placement to the youths.

¶3 After establishing jurisdiction under the Uniform Child-

custody Jurisdiction and Enforcement Act (UCCJEA), the juvenile

court adjudicated the youths dependent and neglected and adopted

treatment plans for both parents.

1 ¶4 The Department later moved to terminate both parents’

parental rights. The youths both supported the termination

motion. Nearly two years after the petition was filed, the juvenile

court terminated mother’s and father’s rights following a contested

hearing. Mother never appeared or participated in the dependency

action and isn’t a party to this appeal.

II. Subject Matter Jurisdiction

¶5 Father first contends that the juvenile court lacked subject

matter jurisdiction under the UCCJEA. We disagree.

A. Standard of Review and Relevant Law

¶6 We review de novo whether the juvenile court had subject

matter jurisdiction under the UCCJEA. People in Interest of B.H.,

2021 CO 39, ¶ 27. When a juvenile court makes factual findings

informing the determination of jurisdiction, we defer to such

findings unless they are clearly erroneous. People in Interest of

S.A.G., 2021 CO 38, ¶ 21.

¶7 “The primary aim of the UCCJEA is to prevent competing and

conflicting custody orders by courts in different jurisdictions” and

to “avoid jurisdictional competition over child-custody matters in an

increasingly mobile society.” People in Interest of M.M.V., 2020 COA

2 94, ¶ 17. “To effectuate this purpose, [the UCCJEA] establishes a

comprehensive framework that a Colorado court must follow to

determine whether it may exercise jurisdiction in a child-custody

matter or whether it must defer to a court of another state.” Id.

¶8 A juvenile court may exercise temporary emergency

jurisdiction when “necessary in an emergency to protect the child

because the child . . . is subjected to or threatened with

mistreatment or abuse.” § 14-13-204(1), C.R.S. 2024. Temporary

emergency jurisdiction is limited in time and scope, and “continues

‘only for as long as the emergency exists’ or the child remains

abandoned.” S.A.G., ¶ 30 (citations omitted).

¶9 A court may not terminate parental rights while exercising

temporary emergency jurisdiction unless it finds there is a

continuing abandonment or emergency. Id. at ¶ 35. To otherwise

enter a permanent custody disposition, a juvenile court must assert

non-emergency jurisdiction. Id. at ¶ 26.

¶ 10 When there is an existing child-custody determination made

by another state, as was the case here, the relevant non-emergency

jurisdiction that a juvenile court in Colorado may pursue is

modification jurisdiction. § 14-13-207, C.R.S. 2024. To obtain

3 modification jurisdiction, the court must determine that it has

either home state or significant connection jurisdiction and (1) a

court of the other state determines it no longer has exclusive,

continuing jurisdiction under that state’s law in conformity with

section 14-13-202; (2) a court of the other state determines that a

Colorado court would be a more convenient forum under that

state’s law in conformity with section 14-13-207; or (3) a court of

either state determines that the child and the child’s parents do not

reside in the other state. § 14-13-203, C.R.S. 2024; see also B.H.,

¶¶ 29-33. A Colorado court must communicate with the other state

before obtaining non-emergency jurisdiction and modifying the

existing child-custody determination. People in Interest of C.L.T.,

2017 COA 119, ¶ 23.

¶ 11 Termination of parental rights isn’t a new child-custody

proceeding that requires the juvenile court to re-assess its

jurisdiction under the UCCJEA. S.A.G., ¶ 39 n.3 (“[I]n Colorado, a

motion to terminate parental rights after a child has been

adjudicated dependent and neglected is a request for a remedy, not

the start of a second proceeding.” (citing § 19-3-502(3)(a), C.R.S.

2021)). Thus, if a court properly obtained modification jurisdiction

4 prior to entering adjudications, it need not re-assess jurisdiction

under the UCCJEA before entering a termination judgment. Id.

B. Additional Background

¶ 12 At the shelter hearing, father reported that there was a child-

custody determination made in Indiana as part of his and mother’s

dissolution of marriage. Father later asserted that after the child-

custody determination was made, the youths resided in Alabama

with mother between 2013 and 2018, in Florida with father between

2018 and 2020, and in Alabama with mother between 2020 and

2021. In the fall of 2021, human services in Alabama became

involved with the family and opened a child-protection

investigation. Mother brought the youths to Colorado and left them

with her estranged mother in December 2021. The petition was

filed just a few days later. At that time, father reported that he lived

in South Carolina.

¶ 13 The juvenile court exercised emergency temporary jurisdiction

at the shelter hearing and regularly reviewed and renewed the

emergency temporary jurisdiction while actively working to resolve

the jurisdictional issue.

5 ¶ 14 Based on information provided by the parties, the juvenile

court then communicated, or attempted to communicate, with

judicial officers from four states: Indiana, Florida, Alabama, and

South Carolina. The court initially issued an order under the

UCCJEA reporting on the results of the four UCCJEA conferences

and finding that each state had deferred jurisdiction to Colorado.

The court found that the youths had not resided in Colorado for

182 days and that there was an out-of-state custody determination.

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

Related

People v. Rediger
2018 CO 32 (Supreme Court of Colorado, 2018)
v. Rios
2020 COA 2 (Colorado Court of Appeals, 2020)
in Int. of S.A.G
2021 CO 38 (Supreme Court of Colorado, 2021)
in Int. of B.H
2021 CO 39 (Supreme Court of Colorado, 2021)
People ex rel. A.V.
2012 COA 210 (Colorado Court of Appeals, 2012)
People
2013 COA 73 (Colorado Court of Appeals, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Peo in Interest of MB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-mb-coloctapp-2025.