In the Interest of A.H., Minor Child, C.A., Mother, T.H., Father

CourtCourt of Appeals of Iowa
DecidedJanuary 28, 2015
Docket14-1916
StatusPublished

This text of In the Interest of A.H., Minor Child, C.A., Mother, T.H., Father (In the Interest of A.H., Minor Child, C.A., Mother, T.H., Father) 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.

Bluebook
In the Interest of A.H., Minor Child, C.A., Mother, T.H., Father, (iowactapp 2015).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 14-1916 Filed January 28, 2015

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

C.A., Mother, Appellant,

T.H., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Romonda Belcher,

District Associate Judge.

A mother and father separately appeal the juvenile court’s termination of

their respective parental rights in their minor child. AFFIRMED ON BOTH

APPEALS.

Judy Johnson of Borseth Law Office, Altoona, for appellant mother.

Barbara O. Hoffman, Des Moines, for appellant father.

Thomas J. Miller, Attorney General, Kathrine S. Miller-Todd, Assistant

Attorney General, John P. Sarcone, County Attorney, and Jon E. Anderson,

Assistant County Attorney, for appellee State.

Joseph Strong of the Youth Law Center, Des Moines, attorney and

guardian ad litem for minor child.

Considered by Vogel, P.J., and Vaitheswaran and Potterfield, JJ. 2

POTTERFIELD, J.

A mother and father separately appeal the juvenile court’s termination of

their respective parental rights in their minor child.

I. Factual and Procedural Background

The child was born on April 20, 2013. Concerns soon arose regarding the

parents’ substance abuse and incidents of domestic violence in the home. The

child was removed from the parents’ custody on June 28, 2013. The child was

placed in the care of her maternal grandparents. The father was arrested the

following month and has remained in the custody of the State since that time. He

is currently on parole and resides at the Salvation Army Rehabilitation Center.

Since the child was removed from the parents’ custody, the mother has

oscillated between periods of sobriety and substance abuse. At times she will

comply with substance testing and demonstrate her sobriety, but at other times

she will avoid testing or return results positive for methamphetamine or other

substances. In September and October 2013, she underwent intensive inpatient

treatment for substance abuse. On March 1, 2014, the mother was arrested for

theft. On March 12, 2014, she was admitted to Broadlawns Emergency Crisis

Unit as she was experiencing hallucinations. She tested positive for marijuana

and amphetamines. In June 2014, she stopped attending visitations and fell out

of contact with her parents. The mother had no contact with service providers

until August 2014. She was asked to submit to a drug screen, and she refused.

She consented to a screen a month later.

Following a review hearing in August 2014, the State petitioned the

juvenile court to terminate both parents’ parental rights. The court terminated 3

parental rights in the child on November 4, 2014. Both the mother and father

appeal.

II. Standard and Scope of Review

We review the juvenile court’s termination order de novo. In re A.M., 843

N.W.2d 100, 110 (Iowa 2014).

III. Discussion

Termination of parental rights follows a three-step analysis. In re D.W.,

791 N.W.2d 703, 706 (Iowa 2010). First, the juvenile court must establish a

statutory ground upon which it bases its termination order; second, the court

must determine whether termination is in the child’s best interest; third, it must

consider whether any mitigating factors should nevertheless prevent it from

terminating the parents’ rights. Id. at 706–07.

A. Grounds for Termination

The mother and father both assert the statutory grounds upon which the

juvenile court based its termination order are not supported by clear and

convincing evidence. “We will uphold an order terminating parental rights if there

is clear and convincing evidence of grounds for termination.” Id. at 706.

“Evidence is ‘clear and convincing’ when there are no serious or substantial

doubts as to the correctness [of] conclusions of law drawn from the evidence.”

Id. We may affirm the termination order if we find any one of the grounds relied

upon is supported by clear and convincing evidence. See id. at 707. 4

One of the statutory grounds relied upon by the juvenile court was Iowa

Code section 232.116(1)(e) (2013).1 Both the mother and father claim they have

maintained significant and meaningful contact with the child contrary to the

juvenile court’s conclusions of law.

We find there is clear and convincing evidence that the parents have not

maintained significant and meaningful contact with the child. As to the father’s

claim, the district court noted he had attended only a single visitation in the two

months prior to the termination order. He visited the child ten times total in fifteen

months. The father’s limited contact with the child does not reflect a genuine

effort to establish or maintain a place of importance in the child’s life or an

affirmative assumption by the father of the duties encompassed by the role of

being a parent. We affirm the district court’s finding of clear and convincing

1 Iowa Code section 232.116(1)(e) provides: [T]he court may order the termination of both the parental rights with respect to a child and the relationship between the parents and the child [if] . . . [t]he court finds that all of the following have occurred: (1) The child has been adjudicated a child in need of assistance pursuant to section 232.96. (2) The child has been removed from the physical custody of the child’s parents for a period of at least six consecutive months. (3) There is clear and convincing evidence that the parents have not maintained significant and meaningful contact with the child during the previous six consecutive months . . . . “[S]ignificant and meaningful contact” includes but is not limited to the affirmative assumption by the parents of the duties encompassed by the role of being a parent. This affirmative duty, in addition to financial obligations, requires continued interest in the child, a genuine effort to complete the responsibilities prescribed in the case permanency plan, a genuine effort to maintain communication with the child, and requires that the parents establish and maintain a place of importance in the child’s life. It is uncontested the first two elements of this statutory provision have been satisfied. Instead, both parents assert they have maintained significant and meaningful contact with the child. 5

evidence to support termination of the father’s parental rights under section

232.116(1)(e).

As to the mother’s claim, the months leading to the termination order

accurately reflect the mother’s overall inconsistency in maintaining a meaningful

relationship with the child. Though she had been visiting the child on a regular

basis in early 2014, she abruptly stopped attending visitations and

communicating with her parents and service providers in June 2014. Once she

was located, DHS noted in a report to the court that she “appeared to be under

the influence of methamphetamine.”

At times, the mother appears to desire to improve her parenting, and she

takes full advantage of available services. However, the episode in June is just

one example in which the mother suddenly abandoned those efforts, stopped

visiting the child, or relapsed into substance abuse. These periods of

abandonment belie the mother’s contention that she has maintained significant

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