JDF 1420: Answer the Modify Motion
JDF 1420 is Colorado's response when the other side has already filed a motion to modify. Your job is to address their requested changes with readable agree-or-disagree positions and proof that matches dates. It is not the moment to file a parallel "whole new case" story like an opening JDF 1413 narrative unless procedure actually calls for it. Reaction discipline beats volume.
| Response posture | Wrong posture |
|---|---|
| Paragraph-by-paragraph position on their relief | Generic "they are awful" without tying to requested orders |
| Exhibits indexed to specific dates and claims | Haystack folders that bury your best facts |
Reaction strip
- 1Highlight every change they want; mark agree, disagree, or partial.
- 2Pull the order language they rely on; note gaps or misreads.
- 3Build a short dated timeline only for disputed facts.
- 4Confirm deadline, service method, and county formatting.
Relevant Colorado law
The statutes and appellate decisions below are the ones Colorado courts actually apply here. Educational orientation only — not legal advice. Read the source before you rely on it.
Statutes
- C.R.S. § 14-10-124 — Best Interests of the Child
The court allocates parental responsibilities, including parenting time and decision-making, in accordance with the best interests of the child, giving paramount consideration to the child's safety and physical, mental, and emotional conditions and needs, and must consider all relevant factors, including the parents' wishes, the wishes of a sufficiently mature child, the child's relationships, adjustment to home, school, and community, the mental and physical health of all involved, each party's ability to encourage the child's contact with the other party, the past pattern of involvement, physical proximity, and each party's ability to put the child's needs ahead of their own. The court may restrict parenting time only if it finds, after a hearing, that parenting time would endanger the child's physical health or significantly impair the child's emotional development; it may not consider conduct that does not affect a party's relationship to the child, and may not presume a person is better able to serve the child's interests because of that person's sex. Under HB 26-1309 (effective May 27, 2026), the court must make findings by a preponderance of the evidence whether a party committed domestic violence, child abuse or neglect, or sexual assault that resulted in conception of a child; if so, the safety and well-being of the child and abused party is the primary concern, the court must impose parenting time conditions that ensure their safety, and mutual decision-making over the other party's objection is not in the child's best interests unless the court specifically finds it can occur without coercion, intimidation, retaliation, or risk of harm. A party's actions to protect the child from witnessing domestic violence or from abuse or neglect are not counted against that party on the encourage-contact factor. This findings duty arises when evidence of domestic violence, child abuse or neglect, or sexual assault resulting in conception is submitted by a party, a child and family investigator, a parental responsibilities evaluator, or the child's legal representative. If a party is absent or leaves home because of the other party's domestic violence, child abuse or neglect, or sexual assault resulting in conception, that absence is not a factor against them (§ 14-10-124(1.6)(d)), and the court must consider whether to prohibit or restrict the offending party's parenting time (§ 14-10-124(1.6)(c)). When the court orders unsupervised parenting time despite information or a child's accusation of domestic violence, child abuse, child sexual abuse, child emotional abuse, or coercive control, it must state on the record why unsupervised time is in the child's best interests (§ 14-10-124(9)).
- C.R.S. § 14-10-131 — Modification of Custody or Decision-Making Responsibility
After a motion to modify a custody decree or decision-making allocation is filed, whether or not it was granted, no further motion may be filed within two years after disposition unless the court decides, on affidavits, that there is reason to believe continuing the prior order may endanger the child's physical health or significantly impair the child's emotional development. The court may modify decision-making responsibility only if, based on facts that arose since the prior decree or were unknown to the court at that time, a change has occurred in the circumstances of the child or the party allocated decision-making and the modification is necessary to serve the child's best interests. Even then, the court must retain the prior allocation unless the parties agree; the child has been integrated into the petitioner's family with the other party's consent and that warrants modification; a parenting time modification under section 14-10-129 warrants it; a party has consistently consented to the other party making decisions that party was to make individually or the parties were to make mutually; or retaining the allocation would endanger the child's physical health or significantly impair the child's emotional development and the harm of a change is outweighed by its advantage.
Key cases
- In re Marriage of Aldrich, 945 P.2d 1370 (Colo. 1997)
A parent seeking to modify child support bears a heavy burden to prove a substantial and continuing change in circumstances; a guidelines recalculation that changes support by less than ten percent is deemed not substantial and continuing, while one that changes it by more than ten percent creates a rebuttable presumption that modification must be granted. The court must initially apply the guidelines to the evidence of change, but where the moving parent presents no credible evidence of change (here, a claimed income drop contradicted by about $111,000 in unexplained bank deposits and a new home and car) it need not run the guideline calculation before denying the motion. The court is not required to raise modification issues the moving party did not raise, though it has discretion to do so case by case in the child's best interests. Under current section 14-10-122(1)(a), child support requires changed circumstances that are substantial and continuing; the wording 'so substantial and continuing as to make the terms unfair' that Aldrich quoted now applies only to maintenance. Child support may be modified only as to installments accruing after the motion to modify is filed, and a modification is also available when the existing order lacks a medical support provision (§ 14-10-122(1)(a)).
- In re Marriage of Chalat, 112 P.3d 47 (Colo. 2005)
A child-support obligation incorporated into the divorce decree — including an agreed obligation to pay postsecondary (college) expenses — may be modified only on a showing of substantial and continuing changed circumstances; the court keeps continuing jurisdiction, and the child-support guidelines do not by themselves reopen the order.
Related guides
More Colorado forms
State guides (overview)
General support (not Colorado-specific)
Official source
JDF 1420 (PDF): https://www.coloradojudicial.gov/sites/default/files/2023-07/JDF1420.pdf
JDF 1420 questions
What is JDF 1420 actually asking me to do?
Answer the other party's motion to modify with your position on each requested change, tied to dated facts and a small exhibit set. You are in a reaction lane with deadlines, not rewriting the case from zero.
What should I read before I type a single paragraph?
The motion line by line, the current orders they cite, service deadlines, and local rules. Skim-reading the relief requested is how parents accidentally concede half the motion.
How is this different from JDF 1413?
JDF 1413 is an opening allocation petition posture. JDF 1420 responds after someone else already asked the court to change existing orders. Different caption, different reader expectation.
MyCustodyCoach is not a law firm. Court rules, fees, and form versions change by county; confirm what applies to your case with official court resources or counsel you hire.