In the Interest of J.S., G.S., and D.L., Minor Children

CourtCourt of Appeals of Iowa
DecidedSeptember 4, 2024
Docket24-1114
StatusPublished

This text of In the Interest of J.S., G.S., and D.L., Minor Children (In the Interest of J.S., G.S., and D.L., Minor Children) 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 J.S., G.S., and D.L., Minor Children, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1114 Filed September 4, 2024

IN THE INTEREST OF J.S., G.S., and D.L., Minor Children,

C.S., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Mahaska County, Patrick J. McAvan,

Judge.

A mother appeals the order terminating her parental rights to her children.

AFFIRMED.

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

Brenna Bird, Attorney General, and Tamara Knight, Assistant Attorney

General, for appellee State.

Misty White, Sigourney, attorney and guardian ad litem for minor children.

Considered by Ahlers, P.J., and Chicchelly and Buller, JJ. 2

AHLERS, Presiding Judge.

The juvenile court terminated the parental rights of the mother and fathers

of three children, born in 2013, 2017, and 2018. Only the mother appeals. She

contends termination was not in the children’s best interests and she should be

given six additional months to achieve reunification.

We conduct de novo review of orders terminating parental rights. In re Z.K.,

973 N.W.2d 27, 32 (Iowa 2022). The juvenile court’s fact findings do not bind us,

but we give them weight, especially in assessing witness credibility. Id.

The Iowa Department of Health and Human Services became involved with

this family three times before the current proceedings—in 2017 due to the middle

child being born with illegal drugs in the child’s system, in 2018 due to the youngest

child being born with illegal drugs in the child’s system, and in 2019 due to

domestic violence inflicted on the mother by the father of the youngest two

children. The 2019 incident led to children-in-need-of-assistance (CINA)

proceedings. The proceedings were successfully closed in 2020 after the mother

underwent both mental-health and substance-use treatment.

Unfortunately, her success was short-lived. The department got involved

with the family again in 2023 due to the mother’s methamphetamine use, her

physical abuse of the youngest child, and another incident of domestic violence

against the mother by the father of the youngest two children. Because of these

problems, the children were removed and CINA proceedings started. Unlike in the

earlier CINA proceedings, the mother failed to address both her mental-health and

substance-use issues. Due to the lack of progress, the children never returned

home, and termination-of-parental-rights proceedings followed. Following a trial, 3

as noted, the juvenile court terminated the rights of all parents, and the mother

appeals.

Our review of termination-of-parental-rights cases follows a three-step

process of determining (1) whether a statutory ground for termination has been

established, (2) whether termination is in the children’s best interests, and

(3) whether any permissive exception should be applied to preclude termination.

In re A.B., 957 N.W.2d 280, 294 (Iowa 2021). We do not address any step a parent

does not challenge. In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). After addressing

any challenged steps, we then consider any additional claims raised by a parent.

In re J.K.-O., No. 24-0678, 2024 WL 3290381, at *1 (Iowa Ct. App. July 3, 2024).

I. Best Interests

As to the three-step process, the mother challenges only the second step.

She contends the State failed to prove it is in the children’s best interests to

terminate her rights because she has a close relationship with the children. While

we acknowledge the mother has a close relationship with the children, our review

of the record convinces us that it is still in the children’s best interests to terminate

her rights.

The best-interests step in the termination analysis requires us to “give

primary consideration to the child[ren]’s safety, to the best placement for furthering

the long-term nurturing and growth of the child[ren], and to the physical, mental,

and emotional condition and needs of the child[ren].” See Iowa Code § 232.116(2)

(2024). The mother’s instability impedes her ability to provide for the children’s

safety, promote their nurturing and growth, and meet their needs. 4

The mother has had recurring substance-use issues for years. Unlike in the

prior CINA proceedings, the mother has not addressed those issues this time. She

has refused all drug testing requested by the department. The two times she

tested during the fourteen months between the children’s removal and the

termination trial were the two times she completed substance-abuse evaluations.

Both times she tested positive for illegal drugs. And both evaluations

recommended inpatient treatment—treatment the mother did not undertake. In

her testimony at the termination trial, the mother admitted ongoing

methamphetamine use, including as recently as two days before the trial. The

mother’s unmitigated methamphetamine addiction alone supports a finding that

termination of her rights is in the children’s best interests. See In re A.B., 815

N.W.2d 764, 776 (Iowa 2012) (“We have long recognized that an unresolved,

severe, and chronic drug addiction can render a parent unfit to raise children.”).

But there’s more.

The mother has also checked out in terms of complying with services. She

declined to participate in solution-based programming offered to her. She also

declined to obtain a mental-health evaluation despite a history of mental-health

issues and the department’s direction for her to obtain an evaluation. See In re

D.H., No. 18-1552, 2019 WL 156668, at *2 (Iowa Ct. App. Jan. 9, 2019) (collecting

cases and finding failure to meaningfully address mental-health issues to be a

basis for terminating parental rights).

Overall instability is also a problem. Throughout the months leading up to

the termination trial, the mother has incurred a significant number of drug-related

criminal charges that make her future freedom uncertain. She also has income 5

instability. While she lists her employment as being a home-health aide, she has

admitted to service providers that one source of her income is prostitution. This

not only subjects the mother to potential harm, but also to further incarceration.

The mother also has housing instability in that she is significantly behind on her

rent and is at risk of being evicted from her home. She has let an individual stay

at her residence who is known to be a safety risk. This overall instability has

resulted in the mother never progressing to anything less restrictive than

supervised visits. See In re S.L., No. 19-0107, 2019 WL 1055689, at *2 (Iowa Ct.

App. Mar. 6, 2019) (finding a child cannot be returned to a parent’s custody when

the parent has failed to progress past fully supervised visits).

The topic of visits is also an area of concern. The mother has missed a

significant number of visits with the children, which has been hard on the children.

While the children’s angst over missed visits is an indication of the closeness of

their relationships with the mother, it also demonstrates how devastating the

mother’s instability is to the children. And, when visits are held, the interactions

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Related

In the Interest of D.M.
516 N.W.2d 888 (Supreme Court of Iowa, 1994)
In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
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)

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In the Interest of J.S., G.S., and D.L., Minor Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-js-gs-and-dl-minor-children-iowactapp-2024.