In the Interest of G.C., Minor Child

CourtCourt of Appeals of Iowa
DecidedApril 14, 2021
Docket20-1541
StatusPublished

This text of In the Interest of G.C., Minor Child (In the Interest of G.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.

Bluebook
In the Interest of G.C., Minor Child, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-1541 Filed April 14, 2021

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

J.V., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Kimberly Ayotte,

District Associate Judge.

A father appeals the district court order terminating his parental rights.

AFFIRMED.

Eric W. Manning of Manning Law Office, PLLC, Urbandale, for appellant

father.

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

Attorney General, for appellee State.

Mike Bandstra, Des Moines, attorney and guardian ad litem for minor child.

Considered by May, P.J., and Greer and Schumacher, JJ. 2

SCHUMACHER, Judge.

A father appeals the district court order terminating his parental rights. We

find termination of the father’s rights supported by the evidence, an extension of

time for reunification not warranted, and determine none of the permissive

exceptions to termination pursuant to Iowa Code section 232.116(3) (2020) should

be applied. We reject the father’s reasonable-efforts argument. Accordingly, we

affirm the decision of the district court.

I. Background Facts & Proceedings

J.V., biological father, and T.C., mother, are the parents of G.C., born in

2020.1 The child was removed from the parents’ custody shortly after birth

because the mother’s parental rights to two other children had been terminated

shortly before G.C.’s birth and the mother continued to struggle with substance

abuse. In addition, the father’s parental rights to another child had been terminated

in 2017. The father was incarcerated. The parents’ relationship involved incidents

of domestic violence. The child was placed with the maternal grandparents, who

also had custody of a sibling.

On March 27, 2020, the child was adjudicated a child in need of assistance

(CINA), pursuant to Iowa Code section 232.2(6)(c)(2) and (n). The father remained

incarcerated throughout the CINA proceedings on charges of willful injury causing

bodily injury, assault causing bodily injury, and first-degree harassment. On the

issue of visitation, the district court stated:

1 The mother consented to the termination of her parental rights and does not appeal. The child’s legal father, E.R., also consented to the termination of his parental rights and does not appeal. Any reference to “the parents” or “the father” is a reference to the biological father. 3

[The Iowa Department of Human Services (DHS)] has made reasonable efforts with regards to visitation with [the father]. In- person visits were not in [the child’s] best interest given his age, no prior relationship with [the father], the travel distance, and COVID-19 restrictions. DHS sent photos of [the child] to [the father]. The DHS worker provided ongoing communication and updates regarding [the child’s] wellbeing. Between July 1, 2020, through Labor Day, no video visits were allowed at [the father’s] correctional facility. [The father] was transferred to the Iowa State Penitentiary in September 2020. Video visits are allowed there, but, because [the father] has not signed a release, DHS is unable to speak with the prison staff to set visits up.

On September 8, the State filed a petition seeking termination of the

parents’ rights. The father testified he could be released from prison soon.2 The

district court noted the father had been sentenced in 2019 with a three-year

mandatory minimum sentence, so he would not be released until 2022. As

reflected in the transcript from the termination proceedings, the father was

extremely argumentative during the two-day hearing.

The juvenile court terminated the father’s parental rights under section

232.116(1)(b), (e), (g), and (h). The court found termination was in the child’s best

interests. The court declined to apply any of the exceptions in section 232.116(3).

The father now appeals the termination of his parental rights.

II. Standard of Review

Our review of termination proceedings is de novo. In re A.B., 815 N.W.2d

764, 773 (Iowa 2012). The State must prove its allegations for termination by clear

and convincing evidence. In re C.B., 611 N.W.2d 489, 492 (Iowa 2000). “‘Clear

and convincing evidence’ means there are no serious or substantial doubts as to

2 The father’s argument appears to be related to his ability to post an appeal bond rather than release on parole. 4

the correctness [of] conclusions of law drawn from the evidence.” Id. Our primary

concern is the best interests of the child. In re J.S., 846 N.W.2d 36, 40 (Iowa

2014).

III. Reasonable Efforts

The father does not raise reasonable efforts as a separate appeal issue.

However, a reasonable-efforts claim is enmeshed in the father’s arguments

concerning the statutory grounds the district court relied on for termination of the

father’s parental rights. We choose to address the reasonable-efforts assertions

separately from the father’s delineated appeal issues.

“The State must show reasonable efforts as a part of its ultimate proof the

child cannot be safely returned to the care of a parent.” C.B., 611 N.W.2d at 493;

see also Iowa Code § 232.102(7) (providing that if custody is transferred to DHS,

it “shall make every reasonable effort to return the child to the child’s home as

quickly as possible consistent with the best interests of the child”). “The reasonable

efforts concept would broadly include a visitation arrangement designed to

facilitate reunification while protecting the child from the harm responsible for the

removal.” In re M.B., 553 N.W.2d 343, 345 (Iowa Ct. App. 1996).

Although DHS must make reasonable efforts in furtherance of reunification,

with some exceptions not applicable here, parents have a responsibility to object

when they claim the nature or extent of services is inadequate. See C.B., 611

N.W.2d at 493–94. A parent’s objection to the sufficiency of services should be

made “early in the process so appropriate changes can be made.” Id. “In general,

if a parent fails to request other services at the proper time, the parent waives the 5

issue and may not later challenge it at the termination proceeding.” In re C.H., 652

N.W.2d 144, 148 (Iowa 2002).

As part of the father’s statutory-grounds argument, the father asserts DHS

did not make reasonable efforts as “DHS failed to provide reasonable efforts to

facilitate visitation for the father,” and the “failure to provide even minimal contact

or visitation with the child frustrated the stated goal of reunification with the father.”

However, the father thwarted the efforts of DHS to assist in reunification efforts.

The father refused to sign a release to allow DHS to share and receive information

with the facility in which the father was housed, even after such was specifically

ordered by the district court at an August 2020 review hearing. G.C.’s guardian ad

litem inquired of the status of the release at the termination hearing:

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

Related

In the Interest of M.B.
553 N.W.2d 343 (Court of Appeals of Iowa, 1996)
In the Interest of M.M.
483 N.W.2d 812 (Supreme Court of Iowa, 1992)
In the Interest of J.S. & N.S., Minor Children, A.S., Mother
846 N.W.2d 36 (Supreme Court of Iowa, 2014)
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 A.R. and A.R., Minor Children
932 N.W.2d 588 (Court of Appeals of Iowa, 2019)
In the Interest of C.B.
611 N.W.2d 489 (Supreme Court of Iowa, 2000)
In the Interest of C.H.
652 N.W.2d 144 (Supreme Court of Iowa, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of G.C., Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-gc-minor-child-iowactapp-2021.