Peo in Interest of SH

── Peo in Interest of SH ── Court: Colorado Court of Appeals Date: April 23, 2026 Category: General 25CA1734 Peo in Interest of SH 04-23-2026 COLORADO COURT OF APPEALS Court of Appeals No. 25CA1734 Mesa County District Court No. 23JV62 Honorable Matthew D. Barrett, Judge The People of the State of Colorado, Appellee, In the Interest of S.H., E.H., A.H., and V.H., Children, and Concerning S.K., Appellant. JUDGMENT AFFIRMED Division IV Opinion by JUDGE SCHUTZ Freyre and Brown, JJ., concur NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced April 23, 2026 Todd M. Starr, County Attorney, John R. Rhoads, Assistant County Attorney, Grand Junction, Colorado, for Appellee Josie L. Burt, Counsel for Youth, Glenwood Springs, Colorado, for S.H. Jenna L. Mazzucca, Guardian Ad Litem for E.H., A.H., and V.H. Andrew A. Gargano, Office of Respondent Parents’ Counsel, Denver Colorado, for Appellant ¶1 S.K. (mother) appeals the judgment terminating her parent- child legal relationships with S.H., E.H., A.H., and V.H. (the children). We affirm. I. Background ¶2 In August 2022, the Mesa County Department of Human Services initiated a dependency or neglect action, alleging that mother struggled with issues of mental health, substance abuse, domestic violence, and homelessness. The Department removed the children, but after mother agreed to stay at a family shelter and enter into a deferred adjudication agreement, the Department returned the children to her care. In May 2023, the juvenile court dismissed the case at the Department’s request. ¶3 After the initial dependency or neglect case closed, the Department continued to provide the family with services, which they could access on a voluntary basis. Less than two months later, mother was contacted by law enforcement and placed on a mental health hold after an incident in which she believed the family was in danger, ran into the street with the children, and brandished a machete. The Department removed the children again and filed a new petition in dependency or neglect. 1 ¶4 Mother denied the allegations in the petition and asked for a jury trial. After trial, the jury determined that the Department had proven the allegations, and the juvenile court sustained the petition and adjudicated the children dependent or neglected. ¶5 The juvenile court then held a dispositional hearing and adopted a treatment plan for mother that required, among other things, that she complete a psychological evaluation and specialized family assessment, participate in therapeutic parenting time and a parenting class, engage in life skills training, and maintain stable housing and employment. ¶6 In June 2024, the Department moved to terminate mother’s parental rights. The juvenile court held an evidentiary hearing over six days in July 2025. After hearing the evidence, the court determined that, although mother had participated in some of the services provided by the Department, she continued to struggle with the same issues that prompted the dependency or neglect cases. The court then determined that an allocation of parental responsibilities (APR) to either D.M. (maternal grandmother) or S.H. (maternal aunt) was not a less drastic alternative to termination. 2  As a result, the court terminated the parent-child legal relationship between mother and the children. II. In Camera Interview ¶7 Mother asserts that the juvenile court violated her due process right to confrontation and cross-examination when it conducted an in camera interview of her child, E.H. In the alternative, she maintains that, even if she did not have a constitutional right to confront and cross-examine E.H., the court abused its discretion by allowing the i