In the Interest of A.R., Minor Child

CourtCourt of Appeals of Iowa
DecidedJuly 20, 2022
Docket22-0873
StatusPublished

This text of In the Interest of A.R., Minor Child (In the Interest of A.R., 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.R., Minor Child, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0873 Filed July 20, 2022

IN THE INTEREST OF A.R., Minor Child

B.R., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Linn County, Cynthia S. Finley,

District Associate Judge.

A father appeals the termination of his parental rights. AFFIRMED.

John J. Bishop, Cedar Rapids, attorney for appellant father.

Thomas J. Miller, Attorney General, and Ellen Ramsey-Kacena, Assistant

Attorney General, for appellee State.

Kimberly Ann Opatz, Linn County Advocate, Cedar Rapids, attorney and

guardian ad litem for minor child.

Considered by Bower, C.J., and Schumacher and Ahlers, JJ. 2

AHLERS, Judge.

This is a termination-of-parental-rights proceeding in which the juvenile

court terminated the rights of both parents. The child was two years old at the time

of the termination hearing. Only the father appeals, so our discussion focuses

primarily on him.

The family came to the attention of the Iowa Department of Human Services

(DHS) because of reports that the parents were using illegal drugs while caring for

the child and the father assaulted someone in the child’s presence. The DHS

investigation uncovered concerns about the family’s unstable housing and

allegations that the father had sexually abused other children. The State started

child-in-need-of-assistance (CINA) proceedings, and the juvenile court adjudicated

the child to be a CINA. At the time of the CINA dispositional hearing, despite the

noted concerns, the child remained in the parents’ custody in the hope that

services could enable the child to remain there. As part of the CINA adjudication

and disposition, the father was ordered to cooperate with drug testing and

complete a psychosexual evaluation.

Following disposition, the family rarely contacted their service providers,

and the father did not participate in drug testing or complete a psychosexual

evaluation. About two months after the dispositional hearing, the father contacted

the DHS and requested that the child be placed in foster care because the parents

were homeless and unable to care for him. The juvenile court ordered the child

removed from the parents’ custody. The child was placed in foster care. Upon

removal, the child was discovered to be undernourished. 3

Following the child’s removal and placement in foster care, the father failed

to consistently contact and meet with providers. He went several months without

having a visit with the child. The child’s foster parents attempted to assist in

facilitating the visits, but the father acted inappropriately and aggressively, so that

assistance stopped.

In addition to the visitation concerns, the father failed to maintain stable

housing throughout DHS involvement. At the termination hearing, the father

testified he lived in the basement unit of a residence. He planned to stay in that

location indefinitely, but the owner of the home testified that the arrangement would

likely last no more than six months. The father’s employment status and ability to

financially provide for the child also raised concerns. The father’s testimony

regarding his employment situation and his situation in general was contradictory,

and he admitted he “only tell[s] partial truths.” The juvenile court found the father

to be “totally lacking in credibility.”

The child has remained with a foster family since removal and has been

thriving. After months of services being provided, the State filed a petition seeking

termination of the parents’ rights. The mother consented to termination of her

rights. The father resisted. Following a termination hearing, the juvenile court

terminated the rights of both parents. The father appeals. He contends the State

failed to prove the statutory grounds for termination and that termination is not in

the child’s best interests.

I. Standard and Scope of Review

We review termination-of-parental-rights rulings de novo. In re Z.P., 948

N.W.2d 518, 522 (Iowa 2020). We give weight to the juvenile court’s fact findings 4

and credibility determinations, but we are not bound by them. Id. at 522–23. Clear

and convincing evidence must support the grounds for termination. Id. at 523.

Our review of termination-of-parental-rights proceedings follows a three-

step analysis. In re W.M., 957 N.W.2d 305, 313 (Iowa 2021). We first determine

whether a ground for termination has been established under Iowa Code

section 232.116(1) (2022). Id. Next, we consider whether termination is in the

child’s best interests using the standards set by Iowa Code section 232.116(2). Id.

Finally, we consider whether an exception in section 232.116(3) should be applied

to preserve the parent-child relationship. Id. “However, if a parent does not

challenge a step in our analysis, we need not address it.” In re N.N., No. 21-1978,

2022 WL 610318, at *1 (Iowa Ct. App. Mar. 2, 2022) (quoting In re J.P., No. 19-

1633, 2020 WL 110425, at *1 (Iowa Ct. App. Jan. 9, 2020)).

II. Analysis

As mentioned, the father raises challenges to only the first two steps of the

analysis on appeal. We address them separately.

A. Statutory Ground

The father’s rights were terminated pursuant to Iowa Code

section 232.116(1)(h). Termination is permitted on this ground upon proof of four

elements:

(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) 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. 5

(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). The father concedes the first three elements. He

challenges only the fourth. He asserts the child could have been returned to his

custody at the time of the termination hearing. See In re A.M., 843 N.W.2d 100,

112 (Iowa 2014) (holding that “at the present time” means at the time of the

termination hearing).

Following our de novo review, we agree with the juvenile court that the child

could not be safely returned to the father. The DHS had good reason to be

concerned about the father’s drug use, so he was ordered to undergo testing. The

father failed to cooperate with drug testing, which permits a conclusion that test

results would be positive. See In re B.C.-S., No. 21-1817, 2022 WL 946994, at *1

(Iowa Ct. App. Mar. 30, 2022). His failure to submit to drug testing perpetuated

concerns regarding his sobriety.

The father’s history raised concerns of sexual abuse of children and

prompted the need for a psychosexual evaluation, but the father refused to get

one. This refusal added to concerns for the child’s safety.

The father also continued to be aggressive toward service providers and

the child’s foster parents, and he failed to engage in services generally.

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Related

In the Interest of A.M., Minor Child, A.M., Father
843 N.W.2d 100 (Supreme Court of Iowa, 2014)
In the Interest of A.B. & S.B., Minor Children, S.B., Father
815 N.W.2d 764 (Supreme Court of Iowa, 2012)
In the Interest of C.B.
611 N.W.2d 489 (Supreme Court of Iowa, 2000)

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