In this case, the Court of Appeals found that the trial court was not deprived of jurisdiction to terminate parental rights under the UCCJEA when the parents relocated to another state after the child was placed in that state with kin-like providers pursuant to an ICPC.

The UCCJEA provides that a court in another state may determine that the issuing state has no jurisdiction because neither the child nor the parents currently reside in the state, C.R.S. § 14-13-202(1)(b). Regardless, the Court found that, in considering § 19-3-205(1), the purposes of the UCCJEA, and other facts in this case, the Colorado court retained jurisdiction to enter the termination judgment because there were no competing or conflicting child-custody proceedings by courts in another jurisdiction.

Additionally, the Court determined, citing People in Interest of S.A.G., 487 P.3d 677 (Colo. 2021), that the termination proceeding was not a new child-custody proceeding under the UCCJEA requiring a reassessment of jurisdiction, but a rather, the termination was a continuation of the existing dependency and neglect case. As such, the Court held that the trial court maintained its exclusive, continuing jurisdiction under § 19-3-205(1), despite the relocation of the child and the parents to another state during the pendency of the dependency and neglect case.

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