In the Interest of G.M., Minor Child

CourtCourt of Appeals of Iowa
DecidedMay 11, 2022
Docket22-0496
StatusPublished

This text of In the Interest of G.M., Minor Child (In the Interest of G.M., 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 G.M., Minor Child, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0496 Filed May 11, 2022

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

Z.M., Father, Appellant,

E.M., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Pottawattamie County, Scott Strait,

District Associate Judge.

Parents separately appeal the termination of their parental rights.

AFFIRMED ON BOTH APPEALS.

J. Joseph Narmi, Council Bluffs, for appellant father.

Kyle E. Focht of Focht Law Office, Council Bluffs, for appellant mother.

Thomas J. Miller, Attorney General, and Mary A. Triick, Assistant Attorney

General, for appellee State.

Roberta J. Megel of Public Defender Office, Council Bluffs, attorney and

guardian ad litem for minor child.

Considered by Greer, P.J., Chicchelly, J., and Mullins, S.J. *

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2022). 2

MULLINS, Senior Judge.

Parents separately appeal the termination of their parental rights to their

child, born in 2021, pursuant to Iowa Code section 232.116(1)(e) and (h) (2021).

While the father entitles his arguments as challenges to the sufficiency of the

evidence supporting the grounds for termination and the juvenile court’s best-

interests determination, the substance of those arguments really only suggests

that, in light of his cognitive issues, the State failed to make reasonable efforts at

reunification and he should have been granted additional time at reunification. He

also requests the application of the statutory exception to termination contained in

Iowa Code section 232.116(3)(c) based on alleged detriment to the child resulting

from severance of the parent-child bond. For her part, the mother argues the

evidence was insufficient to support termination, termination should have been

averted pursuant to section 232.116(3)(c), and she should have been granted

additional time to work toward reunification.

I. Background

The child was born in April 2021. Medical providers observed hostile

tendencies on the part of the father in the child’s presence at the hospital. Various

concerns about the parents’ ability to properly care for the child were also noted.

The mother left the hospital against medical advice and attempted to sign the child

out of the hospital as well. Due to the father’s anger issues, both parents mental-

health and cognitive issues, and their inability to provide safe care for the child, a

physician took the child into protective custody. The Iowa Department of Human

Services (DHS) became involved, and the State sought and obtained an order for 3

temporary removal. The court subsequently adjudicated the child as in need of

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

The parents began attending supervised visits and participating in a safe-

care program. While the parents consistently attended visits early on, the

supervisor reported they “often struggle[d]” and frequently needed to be reminded

to support the child’s head and not leave her unattended. The parents’ attendance

at visitations waned as time marched forward. The parents made “limited

progress” toward the safe-care goal of learning how to care for an infant. Their

progress in safe care did not improve for the remainder of the CINA proceeding.

The parents did not comply with ongoing recommendations to obtain psychological

evaluations and IQ testing or complete a parenting course. Their housing situation

remained unstable despite receiving services aimed at rectifying that situation.

They blamed their inability to obtain housing on the father’s status as a sex

offender. The parents eventually moved to Nebraska, which created additional

difficulties with their ability to attend visits. Ultimately, following a November

permanency-review hearing, the court found the parents “have been unable to

demonstrate any substantial progress for reunification” and ordered the State to

initiate a termination proceeding. The State did so in December.

By the time of the January 2022 termination trial, the mother only recently

reported she obtained an apartment. The apartment was in Nebraska and had yet

to be furnished. The father had been released from jail for a probation violation

the day before the hearing. He had not had any contact with the child for more

than a month. The social worker testified to her opinion that the child could not be

returned to either parent’s care because they are incapable of providing adequate 4

care or rudimentary necessities for this young child. She also opined additional

time would not alleviate the need for removal. The mother testified to her plans to

comply with prior recommendations regarding services, and she agreed it would

be “several months” before the child could be returned to her care. The father also

insisted he was ready to get things squared away as far as service-

recommendations go, and he opined the child could be placed in the parents care

in “about April.” The mother was also pregnant with a second child, and she was

due to give birth in May.

The court ultimately terminated the parents’ rights finding, based on the

parents’ failure to comply with service recommendations aimed at reunification,

“that both parents have failed to place themselves in a position to safely and

appropriately care for their minor child.”

Both parents appeal.

II. Standard of Review

We review termination proceedings de novo. In re A.B., 956 N.W.2d 162,

168 (Iowa 2021); In re C.Z., 956 N.W.2d 113, 119 (Iowa 2021). Our primary

consideration is the best interests of the child, In re J.E., 723 N.W.2d 793, 798

(Iowa 2006), the defining elements of which are the child’s safety and need for a

permanent home. In re H.S., 805 N.W.2d 737, 748 (Iowa 2011).

III. Discussion

A. Reasonable Efforts

We begin with the father’s claim that the DHS did not make reasonable

efforts at reunification. He argues the DHS “threw in the towel on these low

functioning people without ever really working with them and giving them a 5

chance.” But the father does not offer an opinion on what additional services

should have been provided. And, as the State points out, the father did not raise

a complaint regarding the sufficiency of reunification efforts until the termination

hearing, which is too late to preserve error. See In re A.A.G., 708 N.W.2d 85, 91

(Iowa Ct. App. 2005). Furthermore, the record belies the father’s reasonable-

efforts challenge. Various services were court ordered or recommended by DHS,

and the father did not meaningfully follow through. Of the services in which he did

participate, he showed little, if any, progress.

B. Grounds for Termination

As noted, the juvenile court terminated both parents’ rights under Iowa Code

section 232.116(1)(e) and (h). The mother challenges the sufficiency of the

evidence supporting both grounds.

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