People in Interest of C.N.T.

── People in Interest of C.N.T. ── Court: Colorado Court of Appeals Date: June 04, 2026 Category: General The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion. SUMMARY June 4, 2026 2026 COA 47 No. 25CA1563, People in Interest of C.N.T. — Juvenile Court — Dependency and Neglect — Termination of the Parent-Child Legal Relationship — Guardian ad Litem — Standing In this dependency and neglect appeal, a division of the court of appeals considers whether a guardian ad litem (GAL) has standing to file a motion to terminate parental rights. The division concludes that a GAL has standing because (1) People in Interest of R.M.P., 2025 CO 34, applies only to the first, or adjudicatory, phase of a dependency or neglect proceeding and not to the second, or dispositional, phase of a dependency or neglect proceeding; and (2) the GAL is acting under their independent statutory charge to advocate for the child’s best interests. The division further rejects the parents’ contentions that the juvenile court erred by (1) terminating their parental rights; (2) finding that the Department made reasonable efforts to rehabilitate them and to reunite them with the child; (3) finding that the father was unfit and that the mother couldn’t become fit within a reasonable time; and (4) finding there was no less drastic alternative to termination. Likewise, the division is unpersuaded by the father’s additional claims that (1) his treatment plan was inappropriate; (2) he substantially complied with his treatment plan; and (3) his counsel provided ineffective assistance. The division affirms the juvenile court’s judgment. COLORADO COURT OF APPEALS 2026 COA 47 Court of Appeals No. 25CA1563 Chaffee County District Court No. 23JV30009 Honorable Dayna Vise, Judge The People of the State of Colorado, Appellee, In the Interest of C.N.T., a Child, and Concerning W.C.T. and N.L.D., Appellants. JUDGMENT AFFIRMED Division I Opinion by JUDGE MEIRINK Lum, J., concurs J. Jones, J., concurs dubitante Announced June 4, 2026 Mannina & Associates, Julie Thomerson, Denver, Colorado, for Appellee Jenna L. Mazzucca, Guardian Ad Litem Andrew A. Gargano, Office of Respondent Parents’ Counsel, Denver, Colorado, for Appellant W.C.T. Just Law Group, LLC, John F. Poor, Denver, Colorado, for Appellant N.L.D. ¶1 W.C.T. (father) and N.L.D. (mother) appeal the juvenile court’s judgment terminating their parent-child legal relationships with C.N.T. (the child). The parents contend, in part, that under People in Interest of R.M.P., 2025 CO 34, ¶ 33, which held that the State is the exclusive party to prosecute a dependency or neglect proceeding, the guardian ad litem (GAL) lacked standing to file a motion to terminate their parental rights. Thus, they argue, the juvenile court lacked subject matter jurisdiction to terminate their parental rights. We disagree and conclude that R.M.P. doesn’t apply for two reasons: (1) R.M.P. applies to only the adjudicatory (first) phase of a dependency or neglect proceeding — and the motion to terminate was filed in the dispositional (second) phase of the proceeding — and (2) the GAL was acting under section 19-3- 203(5), C.R.S. 2025, which charges a GAL to represent the child’s best interests. We affirm.