Peo in Interest of MVOG

CourtColorado Court of Appeals
DecidedSeptember 26, 2024
Docket24CA0370
StatusUnknown

This text of Peo in Interest of MVOG (Peo in Interest of MVOG) 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 MVOG, (Colo. Ct. App. 2024).

Opinion

24CA0370 Peo in Interest of M-VO-G 09-26-2024

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0370 Montrose County District Court No. 23JV30022 Honorable D. Cory Jackson, Judge

The People of the State of Colorado,

Appellee,

In the Interest of M-V.O-G., a Child,

and Concerning O.O. and M.L.O.,

Appellants.

JUDGMENT AFFIRMED IN PART, REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division VII Opinion by JUDGE SCHUTZ Tow and Pawar, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced September 26, 2024

Martha Phillips Whitmore, County Attorney, Julie R. Andress, Deputy County Attorney, Montrose, Colorado, for Appellee

Robert G. Tweedell, Guardian Ad Litem

Padilla Law, P.C., Beth Padilla, Durango, Colorado, for Appellant O.O.

Robin Tieman, Office of Respondent Parents’ Counsel, Boulder, Colorado, for Appellant M.L.O. ¶1 M.L.O. (mother) and O.O. (father) appeal the judgment

adjudicating M-V.O-G. (the child) dependent and neglected. We

affirm the adjudication, but we reverse the disposition and remand

the case to the juvenile court to ensure compliance with 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.

I. Background

¶2 In August 2023, the Montrose County Department of Human

Services filed a petition in dependency and neglect, alleging, among

other things, that mother tested positive for methamphetamine

while at the hospital giving birth to the child and struggled with

mental health issues. As for father, the Department alleged, among

other things, that he demonstrated “erratic behavior at the hospital”

and had “a child welfare history . . . wherein [he] was not compliant

with his treatment plan, specifically substance abuse services.”

¶3 The parents denied the allegations in the petition and asked

for a jury trial to resolve whether the child should be adjudicated

dependent or neglected. At the trial, the Department asserted that

the child was dependent or neglected under section 19-3-102(1)(c),

C.R.S. 2024, which provides that a child is dependent or neglected

1 if “[t]he child’s environment is injurious to his or her welfare.” After

hearing the evidence, the jury returned a verdict in the

Department’s favor. Based on the jury’s verdict, the juvenile court

adjudicated the child dependent and neglected as to both parents

and adopted treatment plans for them.

II. Indian Child Welfare Act

¶4 Mother first asserts that the juvenile court erred because it did

not ensure that the Department exercised 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, as

required by section 19-1-126(3). Because the court did not make

adequate findings prior to or at the dispositional hearing, we reverse

the disposition and remand the case for further proceedings. See

People in Interest of M.V., 2018 COA 163, ¶ 35 (noting that a

dispositional hearing is a child custody proceeding under ICWA, but

an adjudicatory hearing is not), overruled on other grounds by

People in Interest of E.A.M. v. D.R.M., 2022 CO 42.

¶5 For ICWA to apply in a dependency or 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)

2 (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”). To ascertain whether the case involves

an Indian child, a juvenile court must inquire of the parties whether

they know or have reason to know that the child is an Indian child.

§ 19-1-126(1)(a)(I)(A). A mere assertion of potential Indian heritage,

without more, is insufficient to give the court reason to know that

the child is an Indian child. E.A.M., ¶ 56.

¶6 If the juvenile court does not have reason to know but has

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

court must direct a 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. Section 19-1-126(3) provides a flexible

standard that does not require the department to “succeed in its

efforts” or “exhaust every possible option in attempting to do so.”

H.J.B., ¶ 58. Whether the department satisfied its due diligence

obligation is left to the court’s sound discretion. Id.

3 ¶7 At an initial advisement hearing in August 2023, the juvenile

court asked mother whether she had any Native heritage. Mother

stated that her aunt was an enrolled member of a Cherokee tribe.

The court then provided mother with an ICWA assessment form and

asked her to complete it, including any information about her

Native heritage.

¶8 About a month later, mother filed with the juvenile court a

completed ICWA assessment form, but she did not serve the

Department with the form. For reasons unknown, the form listed

two of mother’s older children and their father, none of whom were

subject to these proceedings, rather than the child or father

involved in this case. The form asserted Southern Ute and Ojibwe

heritage for the identified children but only through their father.

But the form asserted mother had Cherokee and Choctaw heritage

and was “a member of a tribe or believed to be eligible for

membership in one or more tribes.” Mother signed the ICWA

assessment form before filing it.

¶9 Apparently believing that mother had not returned the ICWA

assessment form, the Department requested a hearing “for the

purpose of gathering information regarding ICWA.” At the hearing,

4 mother testified that she did not have any Native heritage other

than Cherokee. Neither the court nor the parties asked mother

specifically about her prior written disclosure of Choctaw heritage.

The Department sent notices to the three Cherokee tribes; all three

tribes responded that the child was not a member or eligible for

membership. No ICWA notices were sent to the Choctaw tribe(s).

The juvenile court did not subsequently make any ICWA findings or

determine whether the Department had exercised due diligence

under section 19-1-126(3).

¶ 10 On appeal, mother concedes that the juvenile court did not

have reason to know that the child was an Indian child, but she

maintains that the Department failed to exercise due diligence

under section 19-1-126(3) by not investigating mother’s assertion

that the child had Southern Ute, Ojibwe, or Choctaw heritage. She

further asserts that we should remand the case for the court to

make findings on whether the Department exercised due diligence.

¶ 11 If section 19-1-126(3) applies, then “the juvenile court must

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

Related

People in Interest of DLR
638 P.2d 39 (Supreme Court of Colorado, 1981)
People Ex Rel. A.G.-G.
899 P.2d 319 (Colorado Court of Appeals, 1995)
People v. INTEREST OF TT
128 P.3d 328 (Colorado Court of Appeals, 2005)
K.D. v. People
139 P.3d 695 (Supreme Court of Colorado, 2006)
People In the Interest of A.W., a Child, and Concerning A
2015 COA 144 (Colorado Court of Appeals, 2015)
In re Estate of Ramstetter v. Hostetler
2016 COA 81 (Colorado Court of Appeals, 2016)
People Ex Rel. G.E.S.
2016 COA 183 (Colorado Court of Appeals, 2016)
People in Interest of M.V
2018 COA 163 (Colorado Court of Appeals, 2018)
People ex rel. M.W.
140 P.3d 231 (Colorado Court of Appeals, 2006)
People ex rel. S.G.L.
214 P.3d 580 (Colorado Court of Appeals, 2009)
People ex rel. A.V.
2012 COA 210 (Colorado Court of Appeals, 2012)
People ex rel. N.G.
2012 COA 131 (Colorado Court of Appeals, 2012)
People v. Poe
2012 COA 166 (Colorado Court of Appeals, 2012)
People ex rel. S.N.
2014 COA 116 (Colorado Court of Appeals, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Peo in Interest of MVOG, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-mvog-coloctapp-2024.