Peo in Interest of JV

── Peo in Interest of JV ── Court: Colorado Court of Appeals Date: May 21, 2026 Category: General 25CA1846 Peo in Interest of JV 05-21-2026 COLORADO COURT OF APPEALS Court of Appeals No. 25CA1846 Arapahoe County District Court No. 22JV216 Honorable Bonnie McLean, Judge The People of the State of Colorado, Appellee, In the Interest of J.V., a Child, and Concerning B.A.F.S. and W.V., Appellants. JUDGMENT AFFIRMED Division I Opinion by JUDGE DUNN J. Jones and Fox, JJ., concur NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 21, 2026 John Christofferson, Interim County Attorney, Michael J. Valentine, Deputy County Attorney, Sylvia Geiger, Assistant County Attorney, Aurora, Colorado, for Appellee Debra W. Dodd, Guardian Ad Litem Robin Tieman, Office of Respondent Parents’ Counsel, Boulder, Colorado, for Appellant B.A.F.S. Joel M. Pratt, Office of Respondent Parents’ Counsel, Colorado Springs, Colorado, for Appellant W.V. ¶1 W.V. (father) and B.A.F.S. (mother) appeal the judgment terminating their parent-child legal relationships with J.V. (the child). We affirm. I. Background ¶2 In March 2022, the Arapahoe County Department of Human Services (the Department) received a report that mother was using illicit substances. Following an investigation, the Department removed the child from mother’s care and filed a petition in dependency or neglect. At that time, the Department couldn’t find father, but it soon located him in Florida. Both parents made no- fault admissions to the petition, and the juvenile court adjudicated the child dependent or neglected. ¶3 After a dispositional hearing, the juvenile court adopted treatment plans for the parents. Both plans required the parents to provide protective parenting, participate in family time, demonstrate financial stability, abstain from criminal activity, and remain in contact with the Department. Mother’s treatment plan also required her to address her substance abuse and mental health issues. 1 ¶4 More than two years later, the Department planned to return the child to mother’s care with an allocation of parental responsibilities (APR) between the parents. In anticipation of that goal, the Department completed an “address check” and discovered that mother had been arrested a few months earlier and had an active protection order, which she was violating; as a result, the Department moved to restrict mother’s parenting time to supervised visits. Over the next six months, mother’s participation waned and father didn’t make the necessary arrangements for the child to live with him in either Florida or Colorado. ¶5 In June 2025, the Department moved to terminate the parents’ parental rights. The juvenile court held an evidentiary hearing in August 2025. After hearing the evidence, the court terminated the parent-child legal relationships between the parents and the child. II. Interstate Compact on the Placement of Children (ICPC) ¶6 Father asserts that the juvenile court erred by requiring an ICPC home study before placing the child in his care in Florida. In the alternative, he maintains that the Department failed to make 2  reasonable efforts to rectify the ICPC denial. We aren’t persuaded by either argument. ¶7 We review de novo whether the juvenile court properly applied the ICPC. People in Interest of O.J.R., 2025 COA 78, ¶ 13. Whether a department satisfied its obligation to make reasonable efforts is a mixed question of fact and law. People in Interest of A.S.L., 2022 COA 146, ¶ 8. We review the court’s factual findings for clear error and review de novo its legal determination. Id. ¶8 The ICPC is an interstate agreement that facilitates the placement and provision of services to child