In the Interest of A.B., Minor Child

CourtCourt of Appeals of Iowa
DecidedJanuary 12, 2022
Docket21-1495
StatusPublished

This text of In the Interest of A.B., Minor Child (In the Interest of A.B., Minor Child) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In the Interest of A.B., Minor Child, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1495 Filed January 12, 2022

IN THE INTEREST OF A.B., Minor Child,

K.R., Mother, Appellant,

R.B., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Lee (South) County, Clinton R.

Boddicker, District Associate Judge.

A mother and father separately appeal the termination of their respective

parental rights. AFFIRMED ON BOTH APPEALS.

Alan Waples, Burlington, for appellant mother.

William (Bill) Monroe, Burlington, for appellant father.

Thomas J. Miller, Attorney General, and Mary A. Triick, Assistant Attorney

General, for appellee State.

Kendra M. Abfalter of Public Defender Office, Burlington, attorney and

guardian ad litem for minor child.

Considered by Vaitheswaran, P.J., and Tabor and May, JJ. 2

MAY, Judge.

A mother and father separately appeal the termination of their respective

parental rights to their child, A.B. Both parents challenge the statutory grounds

authorizing termination and object to the admission of drug-testing evidence. We

affirm.

Our review of termination proceedings is de novo. In re Z.P., 948 N.W.2d

518, 522 (Iowa 2020). “We will uphold an order terminating parental rights where

there is clear and convincing evidence of the statutory grounds for termination.

Evidence is clear and convincing when there is no serious or substantial doubt as

to the correctness of the conclusions of law drawn from the evidence.” In re T.S.,

868 N.W.2d 425, 431 (Iowa Ct. App. 2015) (citation omitted).

Iowa courts use a three-step analysis to review the termination of a parent’s

rights. In re A.S., 906 N.W.2d 467, 472 (Iowa 2018). We must determine whether:

(1) grounds for termination have been established, (2) termination is in the

children’s best interests, and (3) we should exercise any of the permissive

exceptions to termination. Id. at 472–73. “However, if a parent does not challenge

a step in our analysis, we need not address it.” In re J.P., No. 19-1633, 2020 WL

110425, at *1 (Iowa Ct. App. Jan. 9, 2020).

In this case, neither parent addresses the second or third steps. So we

focus on whether statutory grounds for termination were met.

Both parents’ rights were terminated under Iowa Code

section 232.116(1)(h) (2021). It authorizes termination when:

(1) The child is three years of age or younger. (2) The child has been adjudicated a child in need of assistance pursuant to section 232.96. 3

(3) The child has been removed from the physical custody of the child’s parents for at least six months of the last twelve months, or for the last six consecutive months and any trial period at home has been less than thirty days. (4) There is clear and convincing evidence that the child cannot be returned to the custody of the child’s parents as provided in section 232.102 at the present time.

Iowa Code § 232.116(1)(h). Both parents limit their challenges to the last

element.1 It is established when the State demonstrates the child cannot be safely

returned to the parent at the time of the termination hearing. In re T.W., No. 20-

0145, 2020 WL 1881115, at *2–3 (Iowa Ct. App. Apr. 15, 2020).

Like the juvenile court, we conclude A.B. could not be safely returned to

either parent. Both parents have long histories of drug abuse, including

methamphetamine use. Their use continued during this case. In January 2021,

both parents abruptly refused to continue with requested drug screenings. “We

presume these missed drug tests would have resulted in positive tests.” In re I.J.,

No. 20-0036, 2020 WL 1550702, at *2 (Iowa Ct. App. Apr. 1, 2020); accord In re

D.G., No. 20-0587, 2020 WL 4499773, at *4 (Iowa Ct. App. Aug. 5, 2020); In re

L.B., No. 17-1439, 2017 WL 6027747, at *2 (Iowa Ct. App. Nov. 22, 2017). And

1 The mother also argues that the State failed to provide reasonable efforts toward reunification. But this argument is built upon facts outside of our record: The mother focuses on hearings and orders in 2018. But our record contains no filings or transcripts from before July 2019. It almost seems like the mother’s argument was “cut and pasted” from a different case. In any event, given the record before us, we are unable to understand—much less act upon—the mother’s reasonable- efforts argument. So we do not consider any reasonable-efforts challenge. See In re J.J., No. 18-2175, 2019 WL 1055896, at *1 (Iowa Ct. App. Mar. 6, 2019) (“‘To reach the merits of this case would require us to assume a partisan role and undertake the appellant’s research and advocacy. This role is one we refuse to assume.’ It is not our duty to ‘speculate on the arguments [a party] might have made and then search for legal authority and comb the record for facts to support such arguments.’” (alteration in original) (citations omitted)). 4

this presumption was confirmed when both parents later tested positive for

methamphetamine in February 2021, just two months before the start of the

termination hearing. A parent’s methamphetamine use creates a dangerous

environment for children. In re K.L., No. 17-0346, 2017 WL 2465817, at *1 (Iowa

Ct. App. June 7, 2017); In re J.S., 846 N.W.2d 36, 37 (Iowa 2014). This danger

was exemplified when A.B. tested positive for methamphetamine at the beginning

of this case. We expect A.B. would face similar dangers if returned to either parent.

We also note that A.B. has serious health issues that require detailed

attention and diligent care. A.B. receives both occupational and physical therapy

to assist with delayed development. These therapies were not regularly completed

when A.B. was in the mother and father’s care. And once A.B. was placed in foster

care, the mother and father missed many of A.B.’s medical appointments even

though the foster mother provided them with appointment details. Given the

potentially life-threatening implications of A.B.’s health issues, we share the

juvenile court’s concern for A.B.’s safety if he were to be returned to either parent.

The parents also argue that evidence of the February 2021 drug tests was

improperly admitted at trial. The mother contends the evidence lacks foundation2

while the father claims the tests amount to hearsay and lack foundation. While we

review termination proceedings de novo, our review of subsidiary rulings—such as

the admission of evidence—is for an abuse of discretion. In re L.R., No. 13-0713,

2 The mother claims the evidence is “inaccurate,” but she points to no rule of evidence that would permit or require exclusion on this basis. The mother also mentions “hearsay” in passing. But a passing reference does not create a viable argument for our review. See State v. Louwrens, 792 N.W.2d 649, 650 n.1 (Iowa 2010). 5

2013 WL 4504930, at *6 (Iowa Ct. App. Aug. 21, 2013). But see State v.

Dessinger, 958 N.W.2d 590, 597 (Iowa 2021) (“We review hearsay claims,

however, for corrections of errors at law.”). And “[t]he discretionary decisions of

the trial court are presumed to be correct until the contrary is shown by the

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