In the Interest of A.H., Minor Child

CourtCourt of Appeals of Iowa
DecidedDecember 4, 2024
Docket24-1517
StatusPublished

This text of In the Interest of A.H., Minor Child (In the Interest of A.H., 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.H., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1517 Filed December 4, 2024

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

A.M., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Montgomery County, Justin R.

Wyatt, Judge.

A mother appeals the termination of her parental rights. AFFIRMED.

Eric A. Checketts of Checketts Law, PLC, Glenwood, for appellant mother.

Brenna Bird, Attorney General, and Tamara Knight, Assistant Attorney

General, for appellee State.

Ivan Miller of Billings & Mensen, Red Oak, attorney and guardian ad litem

for minor child.

Considered by Buller, P.J., Langholz, J., and Vogel, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

VOGEL, Senior Judge.

After a seven-month-old baby died from injuries consistent with abuse, the

baby’s two-year-old sibling, A.H., was removed from the parents’ custody. While

A.H. was in foster care, the mother did not meaningfully work toward reunification.

The mother forwent mental-health treatment, irregularly participated in family

services, was discharged from substance-use treatment for noncompliance, and

continued to test positive for methamphetamine and cocaine throughout the

juvenile proceeding. The juvenile court ultimately terminated the mother’s parental

rights to now-four-year-old A.H. under Iowa Code section 232.116(1)(e) and (f)

(2024). She appeals.1

On our review, the mother’s ongoing drug use, inability to demonstrate she

can safely parent her child, and failure to progress beyond fully supervised visits

show the child could not have been returned to her custody at the time of the

termination hearing. Thus, the State proved by clear and convincing evidence

termination was warranted under section 232.116(1)(f). Because termination is

also in the child’s best interest and the mother has not shown that any statutory

ground should impede termination, we affirm the juvenile court.

I. Factual Background and Proceedings.

In March 2023, while the mother was at work, A.H.’s seven-month-old

sibling stopped breathing. Yet the father did not call 911 or otherwise seek help

for nearly ten minutes. The baby was life-flighted to Nebraska, where he was

diagnosed with subdural hematoma and a retinal hemorrhage—conditions

1 The father’s parental rights were also terminated in this proceeding, but he does

not appeal. 3

consistent with physical abuse. The baby died a few days later from the injuries.

A.H. was promptly removed from her mother’s and father’s custody and placed

with a foster family, where she has remained ever since. The child was adjudicated

in need of assistance in April.

After removal, the mother tested positive for methamphetamine and

cocaine in July. She again tested positive for methamphetamine in August and

September. During this time, the mother inconsistently attended family-services

appointments and did not obtain a substance-use evaluation.

In October, the Iowa Department of Health and Human Services (HHS) and

the child’s guardian ad litem recommended the juvenile court alter the permanency

goal from reunification to termination. The juvenile court disagreed, explaining the

“case started with the death of a child. The grieving progress undoubtedly caused

[the mother] to engage in services late in the case.” The juvenile court gave the

mother “an additional three months to demonstrate [she] can engage in, and make

significant progress with, reunification services.” Specifically, the mother was

instructed to “consistently attend therapy, treatment, and family centered services.”

Yet the mother did not use this extra time to work toward reunification. She

stopped attending her mental-health appointments altogether. She never

completed the SafeCare program—which provides training on how to safely care

for young children—failing three of the four sections of the assessment after

months of sporadic participation. Indeed, the mother never progressed beyond

fully supervised visits with the child. As for her substance use, the mother was

discharged from her treatment program for noncompliance. She tested positive

for methamphetamine and cocaine in January 2024 and again for 4

methamphetamine in March and April. As a result, the State moved to terminate

the mother’s parental rights.

After a one-day hearing in July, the juvenile court terminated the mother’s

parental rights under Iowa Code section 232.116(1)(e) and (f). In a thorough

ruling, the juvenile court found the mother failed “to complete court-ordered

services, provide consistently negative drug screens, and complete recommended

substance use treatment,” and thus “has made no reasonable efforts to resume

care of the child despite being given additional time to reunify at the permanency

hearing.” The juvenile court also found the child could not be returned to the

mother’s custody at the time of the hearing given her ongoing substance use and

failure to show she can safely parent the child. As for the child’s best interests, the

court concluded the child had been in foster care for fifteen months and “cannot

wait for her parents to learn and consistently demonstrate effective parenting

skills.” The court also found no permissive statutory grounds impeded termination.

Finally, because termination was appropriate, it denied the mother’s request for

another extension of time to work toward reunification.

The mother now appeals.

II. Analysis.

Our statutory termination framework follows a three-step process. Iowa

Code § 232.116(1)–(3). We must consider “(1) whether the State proved any

grounds for termination, (2) whether termination is in the child’s best interests, and

(3) whether any exceptions save the parent–child relationship.” In re W.T., 967 5

N.W.2d 315, 322 (Iowa 2021). We review the juvenile court’s termination order de

novo. In re T.S., 868 N.W.2d 425, 431 (Iowa Ct. App. 2015).

A. Termination under Section 232.116(1)(f).

When a parent’s rights are terminated under multiple statutory grounds, we

may affirm so long as one ground supports termination. In re L.H., 949 N.W.2d

268, 270 (Iowa Ct. App. 2020). We will first consider whether the State proved by

clear and convincing evidence that the mother’s rights should be terminated under

paragraph “f.”

The mother does not challenge the first three elements of paragraph “f”—

the child was over four years old, was adjudicated in need of assistance, and had

been removed from her custody for fifteen straight months. See Iowa Code

§ 232.116(1)(f)(1)–(3). Instead, she only alleges the State failed to prove the child

could not be returned to her custody at the time of the termination hearing. See

id. § 232.116(1)(f)(4). She argues that all drug screens were false positives, she

now resides in a supportive home with her grandmother, and that any lack of

progress was caused by the State’s failure to make reasonable efforts to reunify.

We disagree.

Termination is appropriate if returning the child to the mother’s custody

would expose the child to “any harm amounting to a new child in need of assistance

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Related

In the Interest of N.F.
579 N.W.2d 338 (Court of Appeals of Iowa, 1998)
In the Interest of M.M.
483 N.W.2d 812 (Supreme Court of Iowa, 1992)
In the Interest of M.W. and Z.W., Minor Children, R.W., Mother
876 N.W.2d 212 (Supreme Court of Iowa, 2016)
In the Interests of A.C.
415 N.W.2d 609 (Supreme Court of Iowa, 1987)

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