People In Interest of T.W., a Child

CourtColorado Court of Appeals
DecidedJuly 28, 2022
Docket21CA1331
StatusPublished

This text of People In Interest of T.W., a Child (People In Interest of T.W., a Child) 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 T.W., a Child, (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 July 28, 2022

2022COA88

No. 21CA1331, People in Interest of T.W. — Juvenile Court — Subject Matter Jurisdiction — Authority to Act — Dependency and Neglect — Deferred Adjudication — Allocation of Parental Responsibilities

For the first time since the supreme court’s decision in People in

Interest of J.W. v. C.O., 2017 CO 105, a division of the court of

appeals is required to decide whether a juvenile court is able to

enter an order allocating parental responsibilities under a deferred

adjudication of dependency or neglect. The division concludes that

a juvenile court has continuing subject matter jurisdiction in a

dependency or neglect action after the entry of a deferred

adjudication. However, the division holds that a juvenile court

lacks the legal authority to enter an order for the allocation of

parental responsibilities unless the child has been formally

adjudicated dependent or neglected or the court has accepted an admission from the parents that the child should be adjudicated

dependent or neglected. COLORADO COURT OF APPEALS 2022COA88

Court of Appeals No. 21CA1331 Morgan County District Court No. 20JV26 Honorable Kevin L. Hoyer, Judge

The People of the State of Colorado,

Petitioner,

In the Interest of T.W., a Child,

and Concerning A.M.E.,

Appellant,

And G.U.,

Appellee.

JUDGMENT VACATED AND CASE REMANDED WITH DIRECTIONS

Division I Opinion by JUDGE SCHUTZ Dailey and Fox, JJ., concur

Announced July 28, 2022

Josi McCauley, Guardian Ad Litem

The Law Office of Michael Kovaka, Michael Kovaka, Littleton, Colorado, for Appellant

Bergner Law Office, Stephanie Bergner, Leif Ericson, Carbondale, Colorado, for Appellee ¶1 In this dependency and neglect proceeding, A.M.E. (mother)

appeals the juvenile court’s judgment allocating parental

responsibilities for her child, T.W., to G.U. (father). To resolve

mother’s appeal, we must decide whether a juvenile court may

permanently allocate parental responsibilities when the parties are

proceeding under a deferred adjudication. Because we conclude a

juvenile court lacks the legal authority to enter such an order when

the child has not been adjudicated dependent or neglected, we

vacate the judgment.

I. Procedural History

¶2 In June 2020, the Morgan County Department of Human

Services initiated a dependency and neglect proceeding based on

concerns that the then-ten-year-old child was being mistreated

while in the care of mother and her husband. The child’s father,

who lives in California, had not seen the child in approximately

eight years at the time the case was filed.

¶3 The juvenile court placed the child in the care of his maternal

cousins. The child’s younger half-siblings remained in the custody

of mother and husband. In September 2020, the court accepted

the parties’ stipulation continuing the child’s adjudication and

1 entered an order deferring the issue of whether the child should be

adjudicated dependent or neglected for six months under section

19-3-505(5), C.R.S. 2021. The court also adopted treatment plans

for each parent.

¶4 In the stipulation, the parties set forth their understanding of

how the case would proceed. It provided:

For purposes of this Continued Adjudication only, and no other purpose, [mother and father] knowingly and voluntarily admit the child is a dependent or neglected child because he was in an injurious environment. Respondents also admit the jurisdictional allegations of the Petition. This is a no fault admission and continued adjudication as to . . . mother . . . .

Based upon this limited admission, the parties agreed the court had

continuing jurisdiction to enter temporary placement orders for the

child. But they also expressly agreed that the child was not being

adjudicated dependent or neglected with respect to either parent.

Instead, they agreed that any trial related to whether the child

should be adjudicated dependent or neglected would be continued

— or deferred — for six months.

¶5 In February 2021, father filed a motion seeking an allocation

of parental responsibilities (APR) for the child to him. Mother filed a

2 written objection to father’s APR motion, asserting that father was

not an appropriate placement because he had minimal physical

contact and no emotional bond with the child. Mother requested

the child be placed with her. Soon after, the Department filed a

motion asking the court to adopt its recommended permanency

plan, adjudicate the child dependent or neglected, and grant an

APR to father.

¶6 The court adopted the Department’s proposed permanency

plan, which set the permanent goal as placement of the child with

father in California but with temporary placement remaining with

the child’s cousins while a relationship was established between the

child and father. The court did not address the Department’s

request for an adjudicatory order. Instead, without objection from

the parties, it continued the deferred adjudication for another six

months. It also set a hearing on father’s request for an APR.

¶7 The juvenile court held an evidentiary hearing on father’s APR

motion in June 2021. The court then temporarily placed the child

in father’s custody and authorized video visits with mother. After a

review hearing a couple of months later, the court entered an APR

order that kept the child in father’s custody, authorized parenting

3 time for mother, and awarded decision-making authority between

the parents. The court then certified the APR order into a separate

domestic relations case and closed the dependency and neglect

case.

II. Allocation of Parental Responsibilities

¶8 Mother contends the juvenile court lacked subject matter

jurisdiction to grant the APR because it had not adjudicated the

child dependent or neglected. We conclude the court had

continuing subject matter jurisdiction over the parties and the case

but did not have the legal authority to enter a permanent APR order

for the child. We therefore vacate the juvenile court’s order

allocating parental responsibilities for the child.

A. The Legal Framework

¶9 Dependency and neglect cases spring from foundational

human bonds. There is no relationship more integral to a society

than that of the family. And central to that institution is the

relationship between parents and their children. The Supreme

Court has observed that “the interest of parents in the care,

custody, and control of their children . . . is perhaps the oldest of

the fundamental liberty interests recognized by this Court.” Troxel

4 v. Granville, 530 U.S. 57, 65 (2000). Thus, in the first instance, it is

parents, and not the State, who have the privilege and

responsibility of raising their children.

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People In Interest of T.W., a Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-in-interest-of-tw-a-child-coloctapp-2022.