14 Colorado opinions name it 2 courts 1984–2026 6 in the last five years
The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
C.S. v. Peoplegreen2 sentences2026C.S. v. People, 83 P.3d 627, 636 (Colo. 2004). “[D]ue process requires the appointment of counsel only where the parent’s interests are at [their] strongest, where the state’s interests are at their weakest, and the risks of error are at their peak.” Id. at 636-37 . 2026C.S. v. People, 83 P.3d 627, 636 (Colo. 2004). “[D]ue process requires the appointment of counsel only where the parent’s interests are at [their] strongest, where the state’s interests are at their weakest, and the risks of error are at their peak.” Id. at 636-37 . | 7 | 10 |
People Ex Rel. Mggreen2 sentences2008C.S., 83 P.3d at 637 ; People in Interest of M.G., 128 P.3d 332, 334 (Colo.App.2005) (no due process right to counsel where state sought only to award custody of the child to other individuals). 2008C.S., 83 P.3d at 637; People in Interest of M.G., 128 P.3d 332, 334 (Colo.App.2005) (no due process right to counsel where state sought only to award custody of the child to other individuals). | 2 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Lassiter v. Department of Social Servs. of Durham Cty.
green
2 sentences2021Those factors, which tell courts how much process is due, are "the private interests at stake, the government's interest, and the risk that the procedures used will lead to erroneous decisions." Id. at 27 , 101 S.Ct. 2153 . ¶54 We have interpreted that standard to "require [ ] the appointment of counsel only where the parent's interests are at [their] strongest, where the state 's interests are at their weakest, and the risks of error are at their peak." C.S. , 83 P.3d at 637 ( emphasis added ) . ¶55 Thus, father 's due process claim fails if the risk of an erroneous result at his termination 2021Those factors, which tell courts how much process is due, 24 are “the private interests at stake, the government’s interest, and the risk that the procedures used will lead to erroneous decisions.” Id. at 27 . ¶54 We have interpreted that standard to “require[] the appointment of counsel only where the parent’s interests are at [their] strongest, where the state’s interests are at their weakest, and the risks of error are at their peak.” C.S., 83 P.3d at 637 (emphasis added). ¶55 Thus, father’s due process claim fails if the risk of an erroneous result at his termination hearing was low. | 6 | 2004–2021 |
in Int. of B.H
green
2 sentences2025People in Interest of B.H., 2021 CO 39, ¶ 57 . ¶ 27 Due process requires the appointment of counsel only where “the parent’s interests are at [their] strongest, where the state’s interests are at their weakest, and the risks of error are at their peak.” C.S., 83 P.3d at 637 . 2024Thus, our supreme court has interpreted procedural due process to require the appointment of counsel “only where the parent’s 4 interests are at [their] strongest, where the state’s interests are at their weakest, and the risks of error are at their peak.” Id. at ¶ 54 (quoting C.S. v. People in Interest of I.S., 83 P.3d 627, 637 (Colo. 2004)). ¶8 In termination proceedings, procedural due process is satisfied if a parent is provided with “notice of the allegations in the termination motion, the opportunity to be heard, the opportunity to have counsel if indigent, and the opportunity to call wi | 3 | 2024–2025 |
People in Interest of MM
green
1 sentence2019Id. ¶ 25 Given the lack of protections in kinship adoption proceedings, there is considerable risk of error that can be further compounded for the parent seeking to defend his or her parental rights without the assistance of counsel. ¶ 26 In this case, the risks of error were significant. | 1 | 2019–2019 |
Parham v. J. R.
green
1 sentence1984The court concluded, “[W]e are satisfied that an independent medical decisionmaking process, which includes ... [a] thorough psychiatric investigation..., followed by an additional periodic review of a child’s condition, will protect children who should not be admitted; we do not believe the risks of error in that process would be significantly reduced by a more formal, judicial-type hearing.” Id. 442 U.S. at 613 , 99 S.Ct. at 2509. | 1 | 1984–1984 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.