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In re People in the Interest of S.A.

2022 CO 27. No. 21SA383. Children’s Code—Dependency or Neglect Proceedings—Jurisdiction.

June 13, 2022

In this opinion, the Supreme Court reviewed whether a juvenile court had jurisdiction to enter an order requiring therapeutic visitation between the subject of a dependency or neglect proceeding and his two siblings, who were not adjudicated dependent or neglected. The Court held that no provision of the Colorado Children’s Code, CRS §§ 19-3-100.5 to -905, or the Foster Youth Siblings Bill of Rights, CRS §§ 19-7-201 to -204, granted the juvenile court personal jurisdiction over the siblings. Additionally, the juvenile court’s personal jurisdiction over the child’s parents and subject matter jurisdiction over the proceeding did not extend to allow the court to issue an order requiring the parents to bring the non­dependent siblings to therapeutic visitation.

The Court made the rule to show cause absolute and vacated the juvenile court’s order.

Official Colorado Supreme Court proceedings can be found at the Colorado Supreme Court website.

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