In Interest of AME

── In Interest of AME ── Court: Colorado Court of Appeals Date: April 16, 2026 Category: General 24CA0828 In Interest of AME 04-16-2026 COLORADO COURT OF APPEALS Court of Appeals No. 24CA0828 Douglas County District Court No. 08JV35 Honorable H. Clay Hurst, Judge In the Interest of A.M.E., n/k/a A.M.H., a Child, and Concerning J.L.E., Appellant, and J.J.H., Appellee. APPEAL DISMISSED IN PART, ORDERS AFFIRMED, AND CASE REMANDED WITH DIRECTIONS Division VII Opinion by JUDGE LUM Pawar and Martinez*, JJ., concur NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced April 16, 2026 J.L.E., Pro Se Jennifer Anntoinette Rivera, Denver, Colorado, for Appellee *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 Mother, J.L.E., appeals three orders entered by the district court on March 26, March 27, and April 9, 2024. We dismiss the appeal in part, otherwise affirm the orders, and remand the case to the district court. I. Background A. Procedural History and Prior Appeals ¶2 Mother and J.J.H. (father) have been engaged in a protracted battle over child support arrearages since 2013. ¶3 In 2018, father moved for a satisfaction of judgment, asserting that he had paid his outstanding child support arrearages. In 2021, after significant litigation, the magistrate entered an order granting father’s motion (satisfaction of judgment order). In the satisfaction of judgment order, the magistrate concluded that “there are no outstanding child support arrearages”; entered a satisfaction of judgment; and ordered mother to pay $15,000 of father’s attorney fees under section 13-17-102, C.R.S. 2025. Mother petitioned for review of this order (2021 petition for review), and father requested that the district court award him an additional $3,500 in attorney fees incurred in connection with the 2021 petition of review under section 13-17-102. 1 ¶4 On March 17, 2022, the district court adopted the magistrate’s satisfaction of judgment order. The court remanded the case to the magistrate for a ruling on father’s attorney fees request. The magistrate scheduled a hearing on attorney fees for November 23, 2022. (Meanwhile, mother appealed the district court’s adoption of the magistrate’s satisfaction of judgment order, and a division of this court affirmed. In Interest of A.M.E., (Colo. App. No. 22CA0728, Mar. 9, 2023) (not published pursuant to C.A.R. 35(e)) (A.M.E. I)). ¶5 On October 28, 2022, mother filed a motion to disqualify the magistrate from presiding over all future proceedings in the case, including the attorney fees hearing. ¶6 On November 23, 2022, the magistrate denied mother’s motion to disqualify. We will refer to this order as the “November 23 order.” The attorney fees hearing proceeded as scheduled. ¶7 On November 30, 2022, the magistrate entered an order finding that mother’s actions in filing the 2021 petition for review lacked substantial justification. See § 13-17-102(4). The magistrate awarded father $3,500 in attorney fees incurred in connection with defending against the petition. We will refer to this order as the “November 30 order.” 2 ¶8 Mother timely petitioned the district court for review of the magistrate’s November 23 order. The district court adopted the magistrate’s November 23 order on June 27, 2023. ¶9 Mother appealed the district court’s ruling. See In Interest of A.M.E., (Colo. App. Nos. 23CA1375 & 23CA2187, Apr. 9, 2026) (not published pursuant to C.A.R. 35(e)) (A.M.E. II). During that appeal, a division of this court issued an order for the district court to settle the record and determine whether mother had also timely f