The PEOPLE of the State of Colorado, Petitioner-Appellee, IN the INTEREST OF I.J.O., a Child, and Concerning M.S.O., Respondent-Appellant.
County District Court No. 17JV408 Honorable Katherine R.
M. Miller, County Attorney, Julie Thomerson, Assistant County
Attorney, Westminster, Colorado, for Petitioner-Appellee.
Bradburn, Guardian Ad Litem.
West, Office of Respondent Parents' Counsel, Longmont,
Colorado, for Respondent-Appellant.
OF LIMITED REMAND
1] M.S.O. (mother) appeals the juvenile court's
judgment terminating the parent-child legal relationship
between her and I.J.O. (the child). Mother — who upon
the commencement of and throughout the juvenile court
proceedings was the child's noncustodial natural parent
and lived out of state — frames the issue as whether
the court erred by applying the Interstate Compact on
Placement of Children (ICPC) to the potential placement of
the child with mother. But the substance of her argument is
that the juvenile court erred by permitting the Adams County
Human Services Department to absolve itself of the obligation
to exercise reasonable efforts to rehabilitate mother and to
reunify the family solely because mother failed the ICPC home
2] The division, on its own motion, having
considered the parties' briefs, remands the case to the
juvenile court for the limited purpose of allowing the court
to clarify its findings supporting termination of
mother's parental rights.
3] In December 2017, the Department filed a petition
in dependency and neglect regarding the eight-year-old child.
The Department alleged that the child's father was
unstable and that he was planning to take the child back to
Ohio to live with mother. The Department also alleged that
"[t]his family has [an] extensive child welfare history
in Ohio including a removal from [both mother and
4] The juvenile court adjudicated the child
dependent and neglected. The court adopted a treatment plan
for mother, requiring that she maintain contact with the
Department and provide necessary releases, engage in initial
treatment assessment and planning, abide by any resulting
treatment plan, submit a hair follicle test to determine
whether she had used controlled substances, and cooperate
with an ICPC home study. The plan also called for mother to
have regular telephone contact with the child, although the
juvenile court later suspended these calls because they were
traumatic and dysregulating for the child.
5] In July 2018, the Department moved to terminate
mother's parental rights. In January 2019, following a
hearing, the juvenile court granted the Department's