Peo in Interest of OL-F

CourtColorado Court of Appeals
DecidedNovember 6, 2025
Docket25CA0177
StatusUnpublished

This text of Peo in Interest of OL-F (Peo in Interest of OL-F) 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 OL-F, (Colo. Ct. App. 2025).

Opinion

25CA0177 Peo in Interest of OL-F 11-06-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0177 Adams County District Court No. 21JV285 Honorable Caryn A. Datz, Judge

The People of the State of Colorado,

Appellee,

In the Interest of O.L-F. and C.L-F., Children,

and Concerning R.L. and J.F.,

Appellants.

JUDGMENT AFFIRMED

Division VII Opinion by JUDGE GRAHAM* Lum and Berger*, JJ., concur

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

Heidi Miller, County Attorney, Deborah Kershner, Assistant County Attorney, Westminster, Colorado, for Appellee

Debra W. Dodd, Guardian Ad Litem

The Morgan Law Office, Kristofr P. Morgan, Colorado Springs, Colorado, for Appellant R.L.

Joel M. Pratt, Office of Respondent Parents’ Counsel, Colorado Springs, Colorado, for Appellant J.F.

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025. ¶1 J.F. (father) and R.L. (mother) appeal the judgment

terminating their parent-child legal relationships with O.L-F. and

C.L-F. (the children). We affirm.

I. Background

¶2 In 2019, the Adams County Human Services Department

initiated an action in dependency or neglect involving this family,

which closed about two years later with an allocation of parental

responsibilities (APR). The juvenile court awarded father sole

custody and decision-making authority, while mother received

supervised parenting time. Less than four months later, the

Department filed another petition in dependency or neglect, after

father was arrested for allegedly pointing a firearm at his roommate

in the children’s presence.

¶3 Father admitted to the allegations and agreed to a deferred

adjudication under section 19-3-505(5), C.R.S. 2025, which

required him to comply with a treatment plan that addressed,

among other things, anger management, substance abuse, and

stability. Several months later, the juvenile court revoked father’s

deferred adjudication, adjudicated the children dependent or

neglected, and formally adopted his treatment plan.

1 ¶4 Father appealed the adjudication, asserting, in part, that the

Department had not made reasonable accommodations for his

disability under the Americans with Disabilities Act (ADA). See

People in Interest of O.L-F., slip op. at ¶¶ 19-24 (Colo. App. No.

22CA2208, Aug. 10, 2023) (not published pursuant to C.A.R. 35(e))

(O.L-F. I). The division rejected father’s ADA argument and affirmed

the judgment. Id. at ¶¶ 24, 26.

¶5 Meanwhile, the Department and father’s legal team began

working on amendments to father’s treatment plan that would more

specifically address accommodations for his disability. And in

November 2023, the juvenile court adopted an amended treatment

plan that incorporated those amendments.

¶6 As for mother, the Department could not locate her when it

initiated this case. Mother did not appear at the adjudication

hearing, so the juvenile court entered an adjudication by default

judgment. The court then adopted a treatment plan for mother that

required her to provide for the children’s needs and give them a safe

and stable environment. Mother never appeared in court after her

treatment plan was adopted, and the Department did not have any

contact with her during that time.

2 ¶7 In July 2024, the Department and guardian ad litem filed a

joint motion to terminate the parents’ parental rights. The juvenile

court held an evidentiary hearing over five days in December 2024.

After hearing the evidence, the court entered a thorough, written

order granting the motion and terminating the parent-child legal

relationships between the parents and the children under section

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

II. Reasonable Efforts

¶8 Father asserts that the juvenile court erred by finding that the

Department made reasonable efforts to rehabilitate him and reunify

him with the children. We disagree.

A. Applicable Law and Standard of Review

¶9 Before terminating parental rights under section

19-3-604(1)(c), the juvenile court must find, among other things,

that the parent is unfit. § 19-3-604(1)(c)(II). In assessing a parent’s

fitness, the court should consider whether the department made

reasonable efforts to rehabilitate the parent and reunite the family.

§§ 19-1-103(114), 19-3-208, 19-3-604(2)(h), C.R.S. 2025.

“Reasonable efforts” is defined as the “exercise of diligence and

care” to reunify parents with their children, and the department’s

3 reasonable efforts obligation is satisfied if it provides services in

accordance with section 19-3-208. § 19-1-103(114).

¶ 10 When determined “necessary and appropriate,” the

department must provide (1) screening, assessments, and

individual case plans; (2) home-based family and crisis counseling;

(3) information and referral services; (4) family time; and

(5) placement services. § 19-3-208(2)(b). The juvenile court should

consider whether the services provided were appropriate to support

the parent’s treatment plan, People in Interest of S.N-V., 300 P.3d

911, 915 (Colo. App. 2011), by “considering the totality of the

circumstances and accounting for all services and resources

provided to a parent to ensure the completion of the entire

treatment plan,” People in Interest of My.K.M. v. V.K.L., 2022 CO 35,

¶ 33.

¶ 11 Whether a department satisfied its obligation to make

reasonable efforts is a mixed question of fact and law. People in

Interest of A.S.L., 2022 COA 146, ¶ 8. We review the juvenile

court’s factual findings for clear error and review de novo its legal

determination, based on those findings, as to whether the

department satisfied its reasonable efforts obligation. Id.

4 B. Reasonable Accommodations

¶ 12 Father first contends that the Department failed to make

reasonable efforts because it did not make reasonable

accommodations for him as required by the ADA. We are not

persuaded.

¶ 13 Services provided under section 19-3-208 must comply with

the ADA. See § 19-3-208(2)(g). The ADA mandates that public

entities — such as a county department of human services — make

reasonable modifications to existing policies and services to

reasonably accommodate qualified individuals with disabilities. 42

U.S.C. § 12101(a)(5). A parent may be a qualified individual with a

disability if the parent has a “physical or mental impairment that

substantially limits one or more major life activities.” 42 U.S.C.

§ 12102(1)(A).

¶ 14 A parent is responsible for disclosing information regarding a

disability and any accommodations that are needed to address the

disability. See People in Interest of S.K., 2019 COA 36, ¶ 21.

Whether a parent is a qualified individual with a disability under

the ADA requires a fact-specific determination that, if disputed, the

juvenile court should resolve. See id. at ¶ 21 n.2. And if the court

5 determines that a parent is a qualified individual with a disability, it

must consider whether reasonable accommodations were made for

the parent’s disability when determining whether the department

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