In the Interest of B.H. and J.R., Minor Children

CourtCourt of Appeals of Iowa
DecidedFebruary 6, 2019
Docket18-1251
StatusPublished

This text of In the Interest of B.H. and J.R., Minor Children (In the Interest of B.H. and J.R., Minor Children) 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 B.H. and J.R., Minor Children, (iowactapp 2019).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 18-1251 Filed February 6, 2019

IN THE INTEREST OF B.H. and JR., Minor Children,

J.H., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Wapello County, William Owens,

Associate Juvenile Judge.

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

Mary Baird Krafka of Krafka Law Office, Ottumwa, for appellant mother.

Thomas J. Miller, Attorney General, and Anagha Dixit, Assistant Attorney

General, for appellee State.

Samuel K. Erhardt of Erhardt & Erhardt, Ottumwa, guardian ad litem for

minor children.

Considered by Potterfield, P.J., and Doyle and Tabor, JJ. 2

POTTERFIELD, Presiding Judge.

The mother appeals the termination of her parental rights to B.H. and J.R.,

born in 2008 and 2009, respectively.1 The mother maintains there is not clear and

convincing evidence the children could not be returned to her care at the time of

the termination hearing, termination is not in the children’s best interests, and the

district court erred in admitting hearsay evidence.

I. Background Facts and Proceedings.

This family first came to the attention of the Iowa Department of Human

Services (DHS) in 2009 due to the mother’s use of methamphetamine, concerns

regarding her mental health, and domestic violence in the mother’s romantic

relationship. Both children were adjudicated in need of assistance (CINA) before

DHS ultimately closed the case.

A second case was opened in July 2013, based upon the same issues. The

children were again adjudicated CINA and removed from the mother’s care for a

period of time before DHS closed the second case in August 2015.

The present case was initiated only one month later—in September 2015—

upon allegations the mother was seen leaving a known drug house. The mother

was asked to provide a sample for drug testing, and the result showed the mother

was again using methamphetamine. The mother participated in services, but off

and on for the next two years—until September 2017—the mother either admitted

to use of or tested positive for methamphetamine. During this period, the children

returned to their mother’s care for a short time, but they were removed—for the

1 The parental rights of B.H.’s father were also terminated in this action. He does not appeal. The father of J.R. is deceased. 3

final time—in November 2016, after the mother relapsed again. The court

terminated her parental rights in July 2018 after a termination hearing in May and

June 2018.

It is undisputed the mother did not use methamphetamine from the time she

entered inpatient substance-abuse treatment in mid-September 2017 through the

first day of the termination hearing in mid-May 2018. Still DHS expressed concerns

the mother was engaged in a romantic relationship with a man who continued to

abuse drugs and had an open juvenile court case regarding his children. The

mother was dishonest about the status of her relationship with the man, telling

DHS the two had ended their relationship and then changing the date the

relationship ended after being confronted with evidence they continued to see each

other. Additionally, the family’s social worker was sent a series of messages the

mother and paramour had sent to each other, which established that the mother—

even if not personally using methamphetamine—continued to associate with

individuals who were and was at least considering buying the drug for others.

The second day of the termination hearing took place in mid-June 2018.

The social worker testified the mother had missed her last three scheduled therapy

appointments—attending most recently in late March or early April 2018.

Additionally, the family’s service provider testified he had a parenting class with

the mother a few days before and noticed her pupils looked enlarged. The only

other time the provider had noticed this occurring was when he saw the mother in

September 2015 and made the report that ultimately caused this third case to be

opened—after which the mother tested positive for methamphetamine. The

service provider informed the social worker of his suspicion the mother was under 4

the influence, and the social worker asked the mother to provide a sample for drug

testing later that day when the mother attended family treatment court. She did

not test. At trial, the mother testified she was unable to provide a urine sample at

the time she was asked and did not want to wait until she was able, as she had a

visit with the children scheduled later that afternoon. The mother tested the next

morning, and the test was negative for all substances.

The juvenile court terminated the mother’s parental rights to both B.H. and

J.R. pursuant to Iowa Code section 232.116(1)(f) (2018). The mother appeals.

II. Standard of Review.

“We review termination proceedings de novo.” In re S.R., 600 N.W.2d 63,

64 (Iowa Ct. App. 1999). “The grounds for termination must be proven by clear

and convincing evidence.” Id.

III. Discussion.

First, the mother argues the juvenile court improperly admitted and relied

upon hearsay evidence in allowing the screenshots of messages between her and

the paramour to be admitted into evidence. But evidence that would be excluded

as hearsay in other proceedings is admissible in termination proceedings. See

Iowa Code § 232.96(6) ( “A . . . record, or other writing . . . made by [DHS] . . .

relating to a child in a proceeding under this division is admissible notwithstanding

any objection to hearsay statements contained in it provided it is relevant and

material and provided its probative value substantially outweighs the danger of

unfair prejudice to the child’s parent . . . . The circumstances of the making of the

. . . record or other writing . . . , including the maker’s lack of personal knowledge,

may be proved to affect its weight.”); see also In re E.J.R., 400 N.W.2d 531, 532– 5

33 (Iowa 1987) (concluding that admitting hearsay evidence in juvenile

proceedings “is consistent with the equitable nature of juvenile proceedings which

are designed to retain the advantages for informality while providing safeguards to

guarantee each parties’ fundamental right to a fair hearing”); In re A.J., 553 N.W.2d

909, 916 (Iowa Ct. App. 1996) (providing “reports and information relied upon by

the social worker in carrying out her duties and in testifying at the termination

hearing . . . have previously been held to be admissible over hearsay objections”),

overruled on other grounds by In re P.L., 778 N.W.2d 33, 39 (Iowa 2010). The

juvenile court properly admitted the exhibit containing the messages between the

mother and her paramour, and we consider the evidence as part of the record in

conducting our de novo review.

The juvenile court terminated the mother’s parental rights pursuant to

section 232.116(1)(f), which allows the court to terminate a parent’s rights when it

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In the Interest of E.J.R.
400 N.W.2d 531 (Supreme Court of Iowa, 1987)
In the Interest of A.J.
553 N.W.2d 909 (Court of Appeals of Iowa, 1996)
In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
In the Interest of N.F.
579 N.W.2d 338 (Court of Appeals of Iowa, 1998)
In the Interest of M.S., Minor Child, T.B.-w., Father
889 N.W.2d 675 (Court of Appeals of Iowa, 2016)
In The Interest Of D.W., Minor Child, A.M.W., Mother
791 N.W.2d 703 (Supreme Court of Iowa, 2010)
In the Interest of S.R.
600 N.W.2d 63 (Court of Appeals of Iowa, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of B.H. and J.R., Minor Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-bh-and-jr-minor-children-iowactapp-2019.