Marriage of Li — Appeal dismissed for failure to follow appellate rules

Case
In re the Marriage of Jinghua Zhang and Shuchun Li
Court
Colorado Court of Appeals
Judge
J. Jones; Schock; Sullivan
Date Decided
October 1, 2026
Docket No.
25CA1545
Topics
Family law; Appellate procedure; Permanent orders; Pro se appeals
Source
Read the full opinion

Background

After the parties’ marriage was dissolved in 2019, a prior Colorado Court of Appeals decision vacated the permanent orders and remanded for a new hearing. Wife later moved to California with the parties’ younger child, while husband lived in Ohio with the older child.

Following a two-day permanent-orders hearing, the district court magistrate concluded that parental-responsibilities and child-support jurisdiction would transfer to California, or Ohio if California declined. The magistrate also found Colorado had jurisdiction over the dissolution, property division, and maintenance; found husband had implicitly waived maintenance by not requesting it before the hearing; and equally divided the marital estate, giving each party net equity of $135,667.

The Court’s Holding

The Colorado Court of Appeals dismissed husband’s appeal because his opening brief failed to comply with basic appellate briefing requirements. It lacked record citations, preservation statements, standards of review, and legally and factually developed arguments supporting his claimed grounds for reversal.

The court also held that husband’s self-represented status did not excuse those deficiencies. Further, because he did not provide a transcript of the two-day permanent-orders hearing, the court presumed the missing transcript supported the magistrate’s findings and the regularity of the proceedings.

Key Takeaways

  • An appellant must provide record citations, preservation information, standards of review, and developed legal and factual arguments.
  • Pro se litigants must comply with appellate procedural rules to the same extent as represented parties.
  • Without necessary hearing transcripts, an appellate court presumes the omitted record supports the trial court’s rulings.

Why It Matters

The decision underscores that appellate rules are essential to meaningful review, not technical formalities. A party challenging family-law permanent orders must present a reviewable record and a properly developed appellate brief, or risk dismissal without consideration of the merits.

✉️ Get tomorrow’s cases before your first coffee
Daily Case Law is our free morning digest — the most substantive new decisions, filtered to your jurisdictions and topics, each linking back here for the full analysis.

Leave a Comment

Your email address will not be published. Required fields are marked *

Scroll to Top