In re People in Interest of J.D.

2025 CO 14. No. 24SA193. Statutory Construction—Plain Language—Juvenile Justice—Competency to Stand Trial.

April 14, 2025

The supreme court addressed whether the Children’s Code authorizes the Colorado Department of Human Services to conduct restoration evaluations of juveniles receiving services in its care without a court order authorizing such an evaluation. CRS § 19-2.5-704(2)(b), governing juvenile restoration to competency procedures, provides that “the department is the entity responsible for the oversight of restoration education and coordination of services necessary to competency restoration.” Giving effect to the plain meaning of the statute, the supreme court held that restoration evaluations are included in “services necessary to competency restoration,” and are therefore encompassed by the grant of authority contained in § 19-2.5-704(2)(b).