Peo in Interest of RJM

CourtColorado Court of Appeals
DecidedApril 10, 2025
Docket24CA1114
StatusUnpublished

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

Opinion

24CA1114 Peo in Interest of RJM 04-10-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1114 Moffat County District Court No. 21JV5 Honorable Brittany Schneider, Judge

The People of the State of Colorado,

Appellee,

In the Interest of R.J.M., a Child,

and Concerning R.H.,

Appellant.

JUDGMENT AFFIRMED

Division I Opinion by JUDGE J. JONES Brown and Yun, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced April 10, 2025

Alison D. Casias, Special Assistant County Attorney, Dillon, Colorado, for Appellee

Debra W. Dodd, Guardian Ad Litem

Beth Padilla, Office of Respondent Parents’ Counsel, Durango, Colorado, for Appellant ¶1 In this dependency and neglect proceeding, R.H. (mother)

appeals the judgment terminating her parent-child legal

relationship with R.J.M. (the child). We affirm.

I. Background

¶2 In June 2021, mother was arrested after physically assaulting

the child’s twelve-year-old-sister and the child’s maternal

grandmother. The Moffat County Department of Human Services

then filed a petition in dependency and neglect regarding the then-

six-year-old child, who was present during the assault. The

Department raised concerns about mother’s substance abuse,

domestic violence, and involvement in the criminal justice system.

Initially, the Department placed the child with paternal

grandmother before returning the child to mother’s care. But the

Department later removed the child from mother’s care and again

placed him with paternal grandmother.

¶3 The juvenile court adjudicated the child dependent or

neglected and adopted a treatment plan that required mother to

attend substance abuse treatment and demonstrate sobriety;

refrain from engaging in criminal activity; attend individual therapy;

1 participate in life skills training and parenting classes; complete

domestic violence, psychological, and parenting capacity

evaluations and comply with any recommended treatment; develop

skills to meet the child’s needs; and cooperate with the Department.

¶4 Ten months after the juvenile court adopted mother’s

treatment plan, the Department moved to terminate her parental

rights. Though mother had been representing herself, she

requested court-appointed counsel, which the court granted. At the

Department’s recommendation, the court also appointed a guardian

ad litem (GAL) for mother.

¶5 Within a month of those appointments, mother’s counsel filed

a notice asserting that the Americans with Disabilities Act of 1990

(ADA), 42 U.S.C. §§ 12101-12213, applied to mother. The notice

asserted that mother had “an undiagnosed substance use disorder

and other undiagnosed mental health issues” but did not request

any specific accommodations; rather, it said that her counsel would

confer with the other professionals “should [mother] require any

accommodations or modifications.” Mother’s counsel then moved to

continue the termination hearing because the “professional team

2 need[ed] to determine what accommodations [were] necessary” for

mother. The court granted the continuance, noting that although

mother had not completed a psychological evaluation as required by

the treatment plan, her therapist had recommended a

neuropsychological evaluation, which was already scheduled.

¶6 Mother completed the neuropsychological evaluation in June

2023. However, the evaluation didn’t yield a diagnosis or any

treatment recommendations. Mother’s counsel then moved to

continue the termination hearing again so mother could participate

in a second neuropsychological evaluation. The court granted the

second continuance, and mother completed the second evaluation

in October 2023. Thereafter, mother’s counsel filed a notice of

requested accommodations, which were based on the psychologist’s

recommendations.

¶7 The juvenile court then held a three-day contested termination

hearing. Over two-and-a-half years after the filing of the petition,

the court terminated mother’s parental rights.

3 II. Statutory Criteria and Standard of Review

¶8 The juvenile court may terminate parental rights if it finds, by

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

dependent or neglected; (2) the parent hasn’t complied with an

appropriate, court-approved treatment plan or the plan hasn’t been

successful; (3) the parent is unfit; and (4) the parent’s conduct or

condition is unlikely to change within a reasonable time. § 19-3-

604(1)(c), C.R.S. 2024.

¶9 The question of whether a juvenile court properly terminated

parental rights is a mixed question of fact and law. People in

Interest of S.R.N.J-S., 2020 COA 12, ¶ 10; People in Interest of A.S.L.,

2022 COA 146, ¶ 8. Thus, we review the court’s factual findings for

clear error but review de novo its legal conclusions based on those

facts. S.R.N.J-S., ¶ 10; A.S.L., ¶ 8.

III. ADA Accommodations

¶ 10 Mother contends that the juvenile court erred by finding that

her treatment plan was appropriate and that the Department made

reasonable efforts to rehabilitate her because the Department failed

to provide reasonable accommodations for her disability. We aren’t

persuaded. 4 A. Applicable Law

¶ 11 The ADA requires the juvenile court and the department of

human services to account for and, if possible, make reasonable

accommodations for a parent’s disability when devising a treatment

plan and providing rehabilitative services. People in Interest of S.K.,

2019 COA 36, ¶ 34. But the ADA doesn’t restrict the juvenile

court’s authority to terminate parental rights if a parent, even due

to a disability, isn’t able to meet a child’s needs. People in Interest

of C.Z., 2015 COA 87, ¶ 17. Rather, before terminating parental

rights under section 19-3-604(1)(c), the ADA requires the juvenile

court to consider whether reasonable accommodations were

provided when determining the appropriateness of a parent’s

treatment plan and whether the department made reasonable

efforts to rehabilitate the parent. S.K., ¶ 34.

¶ 12 Whether a parent is a qualified individual with a disability

under the ADA requires a case-by-case determination. Id. at ¶ 21.

Before a department can be required to provide reasonable

accommodations under the ADA, it must know that the individual

has a qualifying disability, either because that disability is obvious

5 or because someone has informed the department of the disability.

Id. at ¶ 22. Thus, while a department must provide appropriate

screening and assessments of a parent, the parent is responsible for

disclosing information regarding her disability. Id. at ¶ 21. And a

parent should also identify any modifications that she believes are

necessary to accommodate her disability. Id.

¶ 13 In considering whether reasonable accommodations can be

made for a parent’s disability, the juvenile court’s paramount

concern must always be the child’s health and safety. Id. at ¶ 36.

Thus, what qualifies as a reasonable accommodation will vary from

case to case based on the child’s needs, the nature of the parent’s

disability, and the available resources. Id. at ¶ 39.

B.

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