In the Interest of J.L., Minor Child

CourtCourt of Appeals of Iowa
DecidedFebruary 19, 2025
Docket24-1811
StatusPublished

This text of In the Interest of J.L., Minor Child (In the Interest of J.L., 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 J.L., Minor Child, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1811 Filed February 19, 2025

IN THE INTEREST OF J.L., Minor Child,

S.W., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Lynn Poschner, Judge.

A mother appeals the termination of her parental rights to her son.

AFFIRMED.

Audra F. Saunders, West Des Moines, for appellant mother.

Brenna Bird, Attorney General, and Michelle R. Becker, Assistant Attorney

General, for appellee State.

Mark D. Reed of Marberry Law Firm, P.C., Urbandale, attorney and

guardian ad litem for minor child.

Considered by Greer, P.J., and Langholz and Sandy, JJ. 2

LANGHOLZ, Judge.

A son and his parents1 came to the attention of the Iowa Department of

Health and Human Services (“HHS”) when the mother was found passed out from

intoxication in her room at a domestic-violence shelter, and the then-three-year-

old son was found wandering unsupervised outside of their room. The son was

eventually removed from his mother’s care. By the termination hearing, there were

still serious concerns about the mother’s substance use and her failure to fully

participate in mental-health therapy.

So the juvenile court terminated the mother’s parental rights.2 And the

mother appeals, arguing that termination is not in the son’s best interest and that

the permissive parent–child bond exception should apply.

But we agree with the juvenile court that termination of the mother’s parental

rights is in the son’s best interest. She has not made progress towards

unsupervised visits, still struggles with substance use, and has not fully utilized

mental-health services. And the son is much improved in his foster-care

placement and is finally experiencing a stable home environment. We also agree

that the parent–child bond exception should not apply because the mother has not

met her burden to prove that termination would be more detrimental to the son

than the uncertain status quo. We thus affirm the juvenile court’s termination of

the mother’s parental rights.

1 We avoid using the parties’ names to respect their privacy because this opinion—

unlike the juvenile court’s order—is public. Compare Iowa Code § 232.147(2) (2024), with id. §§ 602.4301(2), 602.5110. 2 The juvenile court also terminated the father’s parental rights. But he does not

appeal. So we focus on the mother. 3

I. Background Facts and Proceedings

In January 2023, police were called to a domestic-violence shelter where

the mother and son were living. The mother was found unconscious after drinking

a pint of vodka and then taking medication. The son was found wandering around

unsupervised. Later that month, the mother began voluntary services with HHS.

The son’s father was in jail.

In February, the son was placed with his grandmother—apparently under a

safety plan. The mother reported to HHS that she was attending substance-use

treatment and would be starting mental-health treatment soon. And the mother

also reported that the only substance she struggled with was alcohol. Under his

grandmother’s care, the son had his first medical check-up in almost three years,

where he was referred to therapy for an expressive speech delay.

In the spring, the mother regressed with her substance use. At first, she

was compliant with treatment—meeting with her provider, consistently taking her

medication, and submitting random urine tests. But in May, the mother tested

positive for cocaine and cocaine metabolite. So the son was removed from the

mother’s custody and placed in foster care. During a physical exam conducted

after removal, the son tested positive for methamphetamine, cocaine, benzoylec,

methadone, and fentanyl.

The son was adjudicated in need of assistance in June. Though the mother

continued to engage with substance-use treatment, she revoked her release of

information to HHS in August. Later that month, the son was placed with his 4

current foster family.3 Some point later, the mother signed a new release for her

treatment provider to share her information with HHS.

In November, the mother tested positive for cocaine and cocaine

metabolite. And in February 2024, she tested positive for the same plus THC. A

permanency hearing was held over three days in May and June. The court found

that the mother had not fully addressed her substance-use or mental-health issues.

It also noted that the mother had “been closed off and somewhat secretive,” as

she would not talk about the status of her relationship with the father or provide

her address to HHS. The mother had also ignored the physical therapy referral for

the son. And so, the court ordered the State to file a termination petition.

In August, the mother was pulled over while driving with the father, who had

a warrant out for his arrest for violating his probation. He was also under

investigation for distributing fentanyl. The father was arrested, and the police

executed a search warrant at the mother’s home as they had observed he had

been living with her. The officers found thirty-eight fentanyl pills. At the termination

hearing, the mother denied that the father had been living with her and said that

she did not know that there was fentanyl in the apartment.

During this time, the mother was still participating in substance-use services

and meeting monthly with a substance-use counselor. She had also enrolled in

mental-health therapy. Yet the mother tested positive for methamphetamine and

cocaine in July. Indeed, the mother’s substance use precluded any unsupervised

3 Between May and August, the son was shuffled between placements. After removal, he was placed with a foster family. Soon thereafter, he was placed with a relative. But that relative left town in August without telling HHS. So the son was then placed with his current foster family. 5

visits with the son throughout the proceedings. Shortly before the September

termination hearing, the mother tested negative for all substances.

After the hearing, where the son’s guardian ad litem also supported

termination, the juvenile court terminated the mother’s parental rights. In a detailed

decision, the court found that the State proved by clear and convincing evidence

that termination was warranted under Iowa Code section 232.116(1)(f) (2024).

The court also concluded that termination is in the son’s best interest and denied

the mother’s request for six more months to work toward reunification. It found the

mother “denies ongoing drug use or the need for more treatment” and “has

minimally engaged in needed mental health care.” The court emphasized that the

mother “doesn’t see a need for further change” and reasoned that “[t]here is no

reason to think that [the mother] will be able to provide [the son] with [a predictable]

plan in the near future” because she does not see the need for change. And the

court found no permissive exception to termination applied. The mother appeals.

II. Best Interest of the Child

Terminating parental rights under Iowa Code chapter 232 follows a three-

step process. In re L.B., 970 N.W.2d 311, 313 (Iowa 2022). First, the State must

prove a statutory ground for termination. Id.

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Related

In the Interest of C.K.
558 N.W.2d 170 (Supreme Court of Iowa, 1997)
In the Interest of M.W. and Z.W., Minor Children, R.W., Mother
876 N.W.2d 212 (Supreme Court 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)

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