In the Interest of B.C., Minor Child

CourtCourt of Appeals of Iowa
DecidedDecember 4, 2024
Docket24-0680
StatusPublished

This text of In the Interest of B.C., Minor Child (In the Interest of B.C., 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 B.C., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0680 Filed December 4, 2024

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

A.V., Mother, Petitioner-Appellee,

N.C., Father, Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Boone County, Ashley Beisch,

Judge.

The father appeals the termination of his parental rights in a private

termination action. AFFIRMED.

Colin McCormack of Van Cleaf & McCormack Law Firm, LLP, Des Moines,

for appellant.

Jesse A. Macro Jr. of Macro Law, LLP, Des Moines, for appellee.

Kaitlyn Dimaria of Dimaria Law P.L.L.C., West Des Moines, attorney and

guardian ad litem for minor child.

Considered by Greer, P.J., and Buller and Langholz, JJ. 2

GREER, Presiding Judge.

The mother petitioned to terminate the father’s parental rights to B.C., born

in 2018, in a private termination action. See Iowa Code § 600A.5 (2023). The

district court granted the petition on multiple grounds, which the father challenges

on appeal. He argues he did not abandon the child under section 600A.8(3)(b) or

fail to financially contribute to the child without good cause under section

§ 600A.8(4). Both the mother and the child’s guardian ad litem (GAL) filed

appellate briefs in support of the district court’s decision. Following our de novo

review, we affirm.

I. Background Facts and Proceedings.

The mother and father began a romantic relationship in 2017, and B.C. was

born the next year. The parents were married in July 2019; they lived together as

a family for at least a few years. The mother filed for divorce in 2021, and a default

decree was granted. This gave the mother sole legal custody and physical care

of B.C. It also required the father to pay $584.27 per month in child support.

In spite of the divorce decree, the father continued to live with the mother

and B.C. off and on until January 2023. The father was domestically violent toward

the mother, as evidenced by photos introduced at the termination trial, both

parents’ testimony, and text messages showing the father’s apologies for his

actions. B.C. was generally present in the home when the abuse occurred. The

parties cycled through three or four no-contact orders, with the mother repeatedly 3

agreeing to have them dismissed. The mother obtained another no-contact order

in January 20231; she testified this was the last time the father lived in the home.

The mother petitioned to terminate the father’s parental rights in December.

As of the March 2024 termination trial, the mother was remarried; B.C.’s

step-father testified about the “every[ ]day dad duties” he performs and his desire

to adopt B.C. During the father’s testimony, he admitted he physically abused the

mother on “numerous occasions” and belittled B.C., who has been diagnosed with

autism spectrum disorder and attention-deficit/hyperactivity disorder. The father

was engaged in mental-health therapy but conceded that he is still prone to anger

outbursts. Although he had been sporadically employed, he was unemployed at

the time and living at a men’s recovery house (although he did not have issues

with substance abuse). The house manager was a support for the father, and he

supervised the one visit the father set up with B.C.

The district court granted the petition to terminate the father’s parental rights

pursuant to section 600A.8(3)(b) and (4), ruling in part:

[The father] wants what is best for B.C. and loves B.C. in the best way he can. But, many times what actually manifests for [the father] as actions towards B.C. aren’t in B.C.’s best interest. [The father] seemed to acknowledge his limitations in ability to parent and do what’s best for B.C. [He] is not able to provide for B.C. financially, emotionally or for his physical care. What’s best for B.C. is a stable, consistent and loving home—free of aggression and violence.

The father appeals.

1 The no-contact order was later extended and was effective until February 7, 2025. 4

II. Standard of Review.

We review private termination proceedings de novo. In re B.H.A., 938

N.W.2d 227, 232 (Iowa 2020). “Although we are not bound by them, we give

weight to the trial court’s findings of fact, especially when considering credibility of

witnesses.” Id. (citation omitted).

III. Discussion.

“Private termination proceedings under Iowa Code chapter 600A are a two-

step process.” Id. The petitioning parent “must first prove by clear and convincing

evidence the grounds for ordering termination of parental rights.” Id. And second,

they “must prove by clear and convincing evidence that termination is in the best

interest of” the child. Id.

Here, the district court concluded two grounds for termination were

proved—section 600A.8(3)(b) and (4). We may affirm on either ground if we

conclude it is supported by record evidence. See In re B.L.A., 357 N.W.2d 20, 22

(Iowa 1984) (“[I]f one of the grounds for termination is established by clear and

convincing evidence, the termination will be upheld.”). We choose to review

section 600A.8(4), which allows the court to terminate when “[a] parent has been

ordered to contribute to the support of the child or financially aid in the child’s birth

and has failed to do so without good cause.”

The father does not dispute that he was court-ordered to pay $584.27 per

month in child support2 as part of the 2021 decree of dissolution of marriage and

failed to do so—paying only $90.27 through the child support recovery unit from

2 The mother testified this number was calculated based on the father’s job at the

time she petitioned for dissolution, which paid $15 per hour. 5

June 1, 2023, through the termination trial in March 2024.3 Rather, he focuses on

the argument that he has good cause for not paying more. He asserts that due to

a brain injury he suffered in 2014, he is unable to maintain employment, which

prevented him from contributing more to the child financially. According to the

GAL’s report, during his interview, the father told her “he is capable of work, but

that it is difficult to find employment due to his focus, memory and recall issues

related to his brain injury.” Yet, he did not report any recent efforts to find

employment.

Deciding whether a parent is without good cause is a question of fact, and

our inquiry largely focuses on a parent’s ability to pay. See In re R.K.B., 572

N.W.2d 600, 602 (Iowa 1998) (“We described the meaning of ‘without good

cause’ . . . . We indicated ‘the key factual issue . . . concerns the father’s ability to

pay the ordered child support.’” (citations omitted)). The burden is on the

petitioning parent to establish the other parent had the ability to pay child support.

Id. at 601–02. “Although it is not necessary for the petitioner to show that the

parent was willful in failing to pay, the parent’s intent is clearly tied to an ability to

pay.” Id. at 602.

While the father has struggled to maintain constant, full-time employment,

he has had periods of employment earning $15 and even $20 per hour. 4 He also

obtained his commercial driver’s license within the last few years.

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