The People of the State of Colorado, in the Interest of Minor Child: B.h. and B.h., Minor Child v. D.h.

Summary

The court vacated the termination order because the record suggested that an Indiana court may have issued a child-custody determination returning physical custody of B.H. to his parents, yet the district court had not followed the UCCJEA procedures required to modify such an order. The court remanded for jurisdictional factfinding and directed the district court to acquire the required jurisdiction before reinstating the termination judgment. The court otherwise held that denying a third appointed attorney did not violate due process or father's statutory right to counsel, and that the record supported the rejection of less drastic alternatives to termination.