In the Interest of C.C., Minor Child

CourtCourt of Appeals of Iowa
DecidedNovember 23, 2021
Docket20-1716
StatusPublished

This text of In the Interest of C.C., Minor Child (In the Interest of C.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 C.C., Minor Child, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-1716 Filed November 23, 2021

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

C.M., Father, and T.M., Petitioners-Appellees,

S.O., Mother, Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Dallas County, Virginia Cobb, District

Associate Judge.

A mother appeals the termination of her parental rights. REVERSED AND

REMANDED.

Jane M. White of Gribble, Boles, Stewart & Witosky, Des Moines, for

appellant.

Julie A. Forsyth of Forsyth Law Office, P.L.L.C., Winterset, for appellees.

Yvonne C. Naanep, Des Moines, attorney and guardian ad litem for minor

child.

Heard by Vaitheswaran, P.J., and Tabor and May, JJ. 2

MAY, Judge.

The Iowa Indian Child Welfare Act (ICWA)1 imposes special requirements

that must be met before a court may terminate parental rights to an Indian child.2

See, e.g., Iowa Code § 232B.6(6)(a), .10(2). In this case, the juvenile court

terminated a mother’s parental rights to an Indian child. But we conclude ICWA’s

requirements were not met. So we must reverse the termination.

I. Background Facts & Proceedings

This case is about C.C. (the child), born in 2008. The child’s mother is

enrolled in the Rosebud Sioux Tribe (the Tribe). The child is also eligible for

enrollment in the Tribe. The parties agree the child is an “Indian child” for purposes

of ICWA.

In 2019, the child’s father commenced this action to terminate the mother’s

parental rights under Iowa Code chapter 600A, our private termination statute. The

Tribe intervened. A representative of the Tribe appeared at trial. The Tribe

opposed termination of the mother’s parental rights.

Following trial, the court concluded the father had met the requirements of

both chapter 600A and ICWA. So the court terminated the mother’s parental

rights. The mother appeals.

1 The Iowa Indian Child Welfare Act is codified as Iowa Code chapter 232B (2019). Iowa Code § 232B.1. Section 232B.2 states, in pertinent part: “The purpose of the Iowa Indian child welfare Act is to clarify state policies and procedures regarding implementation of the federal Indian Child Welfare Act, Pub. L. No. 95-608, as codified in 25 U.S.C. ch. 21.” 2 Section 232B.3(6) defines “Indian child” as “an unmarried Indian person who is

under eighteen years of age or a child who is under eighteen years of age that an Indian tribe identifies as a child of the tribe’s community.” 3

II. Standard of Review

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

N.W.2d 227, 232 (Iowa 2020). But we review statutory interpretation issues for

correction of errors at law. In re C.A.V., 787 N.W.2d 96, 99 (Iowa Ct. App. 2010).

III. Discussion

On appeal, the mother claims termination was improper because the father

failed to meet the requirements of chapter 600A and ICWA. We begin with the

mother’s argument that the father failed to satisfy ICWA’s qualified-expert-witness

requirement. When a court is “considering whether to . . . terminate the parental

rights of the parent of an Indian child,” section 232B.10(2) obligates (“shall”) the

court to

require that qualified expert witnesses with specific knowledge of the child’s Indian tribe testify regarding that tribe’s family organization and child-rearing practices, and regarding whether the tribe’s culture, customs, and laws would support the . . . termination of parental rights on the grounds that continued custody of the child by the parent . . . is likely to result in serious emotional or physical damage to the child.

See also Iowa Code § 232B.14(2)(g) (requiring “[a] court of competent jurisdiction”

to “vacate a court order and remand the case for appropriate disposition” if there

is a “[f]ailure to provide the testimony of qualified expert witnesses as required by

this chapter”).

In this case, the father did not designate his own “qualified expert witnesses

with specific knowledge of the child’s Indian tribe.” See id. § 232B.10(2). Instead,

the father relied on the testimony of the Tribe’s representative, Shirley Bad Wound.

And it appears undisputed that Bad Wound is a “qualified expert witness” for

purposes of ICWA. See id. § 232B.10 (defining “qualified expert witness” for 4

purposes of ICWA). It also appears undisputed that Bad Wound—the Tribe’s

representative—had “specific knowledge of the child’s Indian tribe.” See id.

§ 232B.10(2).

Instead, the dispute centers on the content of Bad Wound’s testimony. To

be sure, Bad Wound testified about “th[e] [T]ribe’s family organization and child-

rearing practices” as well as other aspects of the Tribe’s culture. See id. But Bad

Wound did not testify as to “whether”—in the words of section 232B.10(2)—“the

[T]ribe’s culture, customs, and laws would support the . . . termination of parental

rights on the grounds that continued custody of the child by the parent . . . is likely

to result in serious emotional or physical damage to the child.” Indeed, the juvenile

court expressly found that Bad Wound “did not give an opinion as to whether not

terminating [the mother’s] parental rights would cause severe emotional or physical

damage to” the child. And the father’s brief acknowledges that Bad Wound

“decline[d] to give an opinion of whether continued custody of [the child] by [the

mother] would result in serious emotional or physical damage.”3

So it appears section 232B.10(2) was not satisfied and, therefore,

termination was improper. Even so, we have carefully considered the father’s

counterarguments. We think they boil down to four points:

1. The purpose of ICWA’s qualified-expert-testimony requirement “is to

provide the court with knowledge of the social and cultural aspects

3 Nor does it appear Bad Wound was prepared to provide that sort of opinion: As the juvenile court found, Bad Wound was not acquainted with the child or the mother. And Bad Wound testified she had received no summary of the family’s information. But it appears Bad Wound had learned some details from the parties’ lawyers. For one thing, she knew the child had been raised by grandparents. 5

of Indian life to diminish the risk of any cultural bias.” See In re

L.N.W., 457 N.W.2d 17, 18 (Iowa Ct. App. 1990) (citation omitted).

2. Bad Wound provided the court with information about “the tribe’s

culture, customs, and laws.” See Iowa Code § 232B.10(2).

3. The juvenile court expressly found “that no cultural bias against” the

mother “as an Indian parent [was] present, either explicitly or

implicitly, in the decision as to whether or not to terminate” the

mother’s rights.

4. Therefore, ICWA’s qualified-expert-testimony requirement was

fulfilled even though Bad Wound did not testify as to whether “the

tribe’s culture, customs, and laws would support the .

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