Background
Jake Reese Leslie and Kristin Faith Leslie married in 2023 and have one daughter. In the 2025 dissolution permanent orders, the magistrate found that father had committed domestic violence against mother and had engaged in coercive control. The court awarded mother primary parenting time and sole decision-making responsibility, while limiting father to supervised visits.
The court’s safety findings included a 2023 incident in which father physically assaulted mother, knocked over mother’s son, and was tasered by police. It also considered father’s assault conviction, his failure to complete required domestic-violence treatment, a pending domestic-violence case involving his current partner, and concerns about safety in father’s home. For child support, the court found father’s monthly gross income was $3,384 and ordered him to pay $709 per month.
The Court’s Holding
The Colorado Court of Appeals affirmed. Although the magistrate did not expressly use the statutory word “endangerment,” its findings sufficiently showed that father’s parenting time would endanger the daughter’s physical health or significantly impair her emotional development. Those findings also adequately explained the supervised-parenting-time restriction.
The court also upheld sole decision-making responsibility for mother. Given the domestic-violence findings and mother’s objection to joint decision-making, the magistrate properly focused on the safety of mother and child and was not required to address every best-interest factor individually. Finally, father could not challenge the $3,384 income finding because he proposed that figure as his “true average income” at the permanent-orders hearing.
Key Takeaways
- Parenting-time restrictions may be affirmed when the court’s findings implicitly, but sufficiently, establish statutory endangerment.
- Domestic violence and an objection to joint decision-making support awarding sole decision-making authority absent credible evidence the parents can safely cooperate.
- A party generally cannot appeal an income determination based on the same income figure the party urged the trial court to adopt.
Why It Matters
The decision illustrates that Colorado family courts need not use talismanic language when imposing parenting-time restrictions, so long as their factual findings demonstrate the statutory basis for the restriction. It also underscores the central role of safety findings in parenting and decision-making orders involving domestic violence.
For child-support litigants, the case is a reminder that positions taken at the permanent-orders hearing can foreclose a contrary argument on appeal.