Supreme Court of Colorado, 1982

The court affirmed judgment for the landlord, holding that the tenant failed to prove that termination of his month-to-month tenancy was retaliatory or discriminatory and that the record supported dismissal of his tort claims.

The court held that due process requires clear and convincing evidence to establish the statutory grounds for terminating parental rights, although the earlier dependency-or-neglect adjudication may be established by a preponderance of the evidence.