In the Interest of I.T., Minor Child

CourtCourt of Appeals of Iowa
DecidedMay 22, 2024
Docket24-0355
StatusPublished

This text of In the Interest of I.T., Minor Child (In the Interest of I.T., 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 I.T., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0355 Filed May 22, 2024

IN THE INTEREST OF I.T., Minor Child,

K.S., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Appanoose County,

Richelle Mahaffey, Judge.

A mother appeals the district court order terminating her parental rights.

AFFIRMED.

Michael S. Fisher of Fisher Law Office, New Sharon, for appellant mother.

Brenna Bird, Attorney General, and Mackenzie L. Moran, Assistant Attorney

General, for appellee State.

Debra A. George of Griffing & George Law Firm, P.L.C., Centerville,

attorney and guardian ad litem for minor child.

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

SCHUMACHER, Judge.

A mother appeals the district court order terminating her parental rights. We

find the termination of the mother’s parental rights is supported by clear and

convincing evidence, termination is in the child’s best interests, and an exception

to termination should not be applied. We affirm the decision of the district court.

I. Background Facts & Proceedings

K.S. is the mother of I.T. who was born in 2021.1 The mother tested positive

for methamphetamine and benzodiazepines at the time of the child’s birth. The

child also tested positive for methamphetamine, amphetamines, and

benzodiazepines in an umbilical cord test. I.T. was removed from the mother’s

custody and placed in a foster home with her biological sibling.2

I.T. was adjudicated to be in need of assistance (CINA). The mother had a

substance-use evaluation and began a treatment program. She also participated

in mental-health treatment. The mother tested positive for methamphetamine in a

hair test in February 2022 and a urine test in March. In September and December,

the mother again tested positive for methamphetamine.

The mother made some progress with services, receiving mental-health

and substance-use treatment. On May 18, 2023, the child began a trial home visit

with the mother. The court returned custody of the child to the mother on June 1.

On August 30, the mother had a miscarriage in another state and tested positive

1 The child’s father is unknown. The parental rights of any putative father were terminated. 2 The child was first placed with relatives but was later moved to the foster home.

The mother’s parental rights to the child’s sibling were terminated in 2020 and he was adopted by the foster family. 3

for methamphetamine. The child was again removed from the mother’s custody

and returned to the foster home where her sibling was residing. The mother

subsequently presented two negative drug tests.

The mother was in a relationship with G.T., who has a history of using

methamphetamine.3 Additionally, there were concerns about domestic violence in

the relationship. At times, the mother was dishonest with case workers from the

Iowa Department of Health and Human Services (HHS) about the status of her

relationship with G.T.

On September 7, the State filed a petition seeking termination of the

mother’s parental rights. In November, the mother had a hair test that was positive

for methamphetamine. At the termination hearing, held in December, the mother’s

therapist, Doug Billingsley, testified he was surprised by the positive drug test in

August, as he did not believe the mother showed signs of active drug use. Michelle

Weldon, the HHS case manager, stated the mother was dishonest about her drug

use. She was also dishonest about her relationship with G.T.

The mother testified she was employed to provide in-home health care. She

stated she was no longer in a relationship with G.T. She denied using drugs when

she tested positive in August and November. The mother asked for the child to be

returned to her custody.

At the termination hearing, the mother sought to introduce Exhibit 31, which

contained reports of two negative drug tests from October and November. These

tests were not random, as they were scheduled by the mother. The State objected

3 The mother initially reported that G.T. was the father of the child, but he was

excluded by paternity testing. 4

on the grounds that the documents appeared to be altered. The court agreed to

leave the record open to give the mother an opportunity to obtain a release from

the lab so the State could obtain the original of the reports. The mother signed a

release, but it was not accepted by the lab. The court granted the mother’s request

for an extension so she could obtain any available information about the drug test

reports. The mother did not obtain any additional information, and her request for

a second extension of time was denied.

The district court terminated the mother’s parental rights under

section 232.116(1)(g) and (h) (2023). The court noted the mother was unable to

be honest about her drug use and this hampered her ability to address the problem.

The court determined the mother’s Exhibit 31 contained unreliable information.

And it found termination of the mother’s parental rights was in the child’s best

interests, as the child needed permanency that the mother was unable to provide.

The court applied none of the exceptions found in section 232.116(3). The mother

now appeals.

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 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). 5

In general, we follow a three-step analysis in reviewing the termination of a

parent’s rights. In re P.L., 778 N.W.2d 33, 39 (Iowa 2010). First, we consider

whether there is a statutory ground for termination of the parent’s rights under

section 232.116(1). Id. Second, we look to whether termination of the parent’s

rights is in the child’s best interests. Id. (citing Iowa Code § 232.116(2)). Third,

we consider whether any of the exceptions to termination in section 232.116(3)

should be applied. Id. But when the parent does not raise a claim relating to any

of the three steps, we do not address that step and instead limit our review to the

specific claims presented. See id. at 40 (recognizing we do not consider a step

the parent does not challenge).

III. Sufficiency of the Evidence

The mother claims the State did not present clear and convincing evidence

to support termination of her parental rights. She asserts the State failed to show

the child could not be returned to her at the time of the termination hearing. The

mother continues to deny the accuracy of the drug test in August 2023. She also

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Related

In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
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.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)

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