In Interest of AME

── In Interest of AME ── Court: Colorado Court of Appeals Date: April 16, 2026 Category: General 23CA1375 & 23CA2187 In Interest of AME 04-16-2026 COLORADO COURT OF APPEALS Court of Appeals Nos. 23CA1375 & 23CA2187 Douglas County District Court No. 08JV35 Honorable H. Clay Hurst, Judge Honorable Ben Leutwyler, 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. ORDERS AFFIRMED AND CASE REMANDED WITH DIRECTIONS Division V Opinion by JUDGE LUM Freyre and Grove, 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 ¶1 Mother, J.L.E., appeals two district court orders adopting orders entered by the magistrate on November 23 and November 30, 2022. We affirm. I. Background and Procedural History ¶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),1 and father requested that the district court award him an additional $3,500 in attorney 1 Mother filed both a petition for review and amended petition for review of the 2021 satisfaction of judgment order. Our reference to the “2021 petition for review” includes both petitions unless stated otherwise. 1  fees incurred in connection with the 2021 petition of review under section 13-17-102. ¶4 On March 17, 2022, the district court adopted the magistrate’s satisfaction of judgment order.2 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 30, 2022. ¶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 (motion to disqualify). Mother also requested attorney fees. ¶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 2 Mother appealed the district court’s order adopting the magistrate’s satisfaction of judgment order. 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)). 2  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.” ¶8 Mother petitioned the district court for review of the magistrate’s November 23 and November 30 orders. On June 27, 2023, the district court adopted the magistrate’s November 23 order. On April 9, 2025, the district court adopted the magistrate’s November 30 order.3 Mother appeals the district court’s adoption of the magistrate’s orders. ¶9 In connection with the November 23 order, mother argues that the district court erred by (1) adopting the magistrate’s ruling denyin