People In Interest of Jay.J.L. and Jac.J.L., Children

CourtColorado Court of Appeals
DecidedApril 14, 2022
Docket21CA0659
StatusPublished

This text of People In Interest of Jay.J.L. and Jac.J.L., Children (People In Interest of Jay.J.L. and Jac.J.L., Children) 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
People In Interest of Jay.J.L. and Jac.J.L., Children, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY April 14, 2022

2022COA43

No. 21CA0659, People in Interest of J.J.L. — American Indian Law — ICWA — Notice; Juvenile Court — Dependency and Neglect — Termination of the Parent-Child Legal Relationship — Compliance with the Federal “Indian Child Welfare Act” — Knows — Reason to Know — Due Diligence

In this dependency and neglect proceeding, a division of the

court of appeals holds that a parent’s assertion of Indian heritage,

standing alone, is not a “reason to know” the child is an Indian

child that triggers the notice requirements of the Indian Child

Welfare Act of 1978, 25 U.S.C. §§ 1901-1963, and section 19-1-126,

C.R.S. 2021. But such an assertion does trigger the petitioning

party’s obligation under section 19-1-126(3) to “exercise due

diligence” to assist the juvenile court in determining whether there

is “reason to know” that the child is an Indian child. The division clarifies section 19-1-126(3)’s due diligence

obligation. Like the division in People in Interest of A-J.A.B., 2022

COA 31, this division concludes that the exercise of due diligence

requires the petitioning party — usually a department of human

services — to follow up with any parent who discloses Indian

heritage to determine the basis of the parent’s belief or

understanding. Unlike A-J.A.B., however, this division concludes

that there is no prescribed set of steps that the department must

follow to satisfy section 19-1-126(3)’s due diligence obligation.

Instead, what constitutes due diligence is flexible and will

necessarily depend on the circumstances of, and the information

presented to the court in, each case.

Because the record in this case does not show that section

19-1-126(3)’s obligation was met, the division remands the case

with instructions for the juvenile court to direct the department to

“exercise due diligence” and assist the juvenile court to properly

determine whether, with more adequate information, there is

“reason to know” that the child is an Indian child under section

19-1-126(3). COLORADO COURT OF APPEALS 2022COA43

Court of Appeals No. 21CA0659 City and County of Denver Juvenile Court No. 19JV1672 Honorable Pax Moultrie, Judge

The People of the State of Colorado,

Appellee,

In the Interest of Jay.J.L. and Jac.J.L., Children,

and Concerning B.J.L. and J.M.G.,

Appellants.

ORDER OF LIMITED REMAND

Division V Opinion by JUDGE YUN Dunn and Welling, JJ., concur

Announced April 14, 2022

Kristin M. Bronson, City Attorney, Amy J. Packer, Assistant City Attorney, Denver, Colorado, for Appellee

Jeffrey C. Koy, Jordan Oates, Lauren Dingboom, Claire Collins, Guardians Ad Litem

Lindsey Parlin, Office of Respondent Parents’ Counsel, Kaneohe, Hawaii, for Appellant B.J.L.

The Morgan Law Office, Kris P. Morgan, Colorado Springs, Colorado, for Appellant J.M.G. ¶1 In this dependency and neglect proceeding, J.M.G. (mother)

and B.J.L. (father) appeal the juvenile court’s judgment terminating

their parent-child legal relationships with J.J.L. (the child). To

decide this appeal, we must dive into the requirements of the Indian

Child Welfare Act of 1978 (ICWA), 25 U.S.C. §§ 1901-1963, and

section 19-1-126, C.R.S. 2021.

¶2 It is well established that when the court knows or has reason

to know that an Indian child is involved in a termination

proceeding, the court must ensure that the party seeking

termination provides notice of the proceeding to the potentially

concerned tribe or tribes. But, in this case, we must determine

whether mother’s assertion of Indian heritage, which she connected

to specific tribal ancestral groups, constituted a reason to know

that the child was an Indian child or, in the alternative, whether it

required the petitioning party to exercise due diligence to gather

additional information under section 19-1-126(3).

¶3 We conclude that a parent’s assertion of Indian heritage,

standing alone, is insufficient to trigger ICWA’s notice requirements

but, rather, it invokes the petitioning party’s obligation to exercise

due diligence under section 19-1-126(3). We further conclude that

1 the exercise of due diligence under this provision is flexible and

depends on the circumstances of, and the information presented to

the court in, each case. Nonetheless, the record needs to show that

the petitioning party earnestly endeavored to gather additional

information that would assist the court in determining whether

there is reason to know that the child is an Indian child.

¶4 Because the record does not demonstrate that the petitioning

party met this obligation, we remand the case to the juvenile court

for further proceedings.

I. The Juvenile Court Proceeding

¶5 In November 2019, the Denver Department of Human Services

filed a dependency and neglect petition concerning the two-year-old

child and a younger sibling who is not subject to this appeal. In the

petition, the department indicated that mother reported having

Cherokee or Navajo heritage but was “uncertain which and does not

know if anyone in her family was an enrolled member.”

¶6 At the initial temporary custody hearing, mother also told the

juvenile court that she had Cherokee or Navajo heritage. The court

determined that this was not reason to know that the child is an

Indian child. Still, it told mother to complete an ICWA ancestry

2 chart and directed the department to exercise due diligence to

gather additional information that would assist it in determining

whether there was reason to know that the child is an Indian child.

¶7 Mother promptly completed and submitted an ICWA inquiry

form, as well as an ICWA ancestry chart. On the form, mother

again indicated that either she or someone in her family had Indian

heritage, but she also checked boxes indicating that she was not

enrolled in an Indian tribe and that the child was neither enrolled

in a tribe nor eligible for enrollment. In the ICWA ancestry chart,

mother identified her tribe as Cherokee, but she did not fill in

additional sections that sought tribal affiliations for the maternal

grandparents and great-grandparents.

¶8 The court adjudicated the child dependent and neglected and

entered dispositional orders concerning both parents. Although the

court did not expressly address ICWA’s applicability as part of the

dispositional orders, it later reiterated that the department should

investigate mother’s claim of Cherokee or Navajo heritage.

¶9 In December 2020, the department moved to terminate the

legal relationships between the child and his parents. As part of its

termination motion, the department asserted that there was no

3 reason to know, based on inquiries of both parents, that the child is

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People In Interest of Jay.J.L. and Jac.J.L., Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-in-interest-of-jayjl-and-jacjl-children-coloctapp-2022.