In the Interest of K.A., Minor Child

CourtCourt of Appeals of Iowa
DecidedApril 24, 2024
Docket24-0287
StatusPublished

This text of In the Interest of K.A., Minor Child (In the Interest of K.A., 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 K.A., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0287 Filed April 24, 2024

IN THE INTEREST OF K.A., Minor Child,

C.C., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Johnson County, Joan M. Black,

Judge.

A mother appeals the termination of her parental rights. AFFIRMED.

Kristin L. Denniger, Mount Vernon, for appellant mother.

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

General, for appellee State.

Sara Strain Linder of Linn County Advocate, Inc., Cedar Rapids, attorney

and guardian ad litem for minor child.

Considered by Tabor, P.J., and Badding and Buller, JJ. 2

BADDING, Judge.

This child-welfare proceeding began and ended with high-speed chases,

with continued instability in between. In May 2023, the mother led police officers

on a high-speed chase while she was intoxicated. Her one-year-old daughter was

in the car with her. The mother was arrested and charged with multiple crimes,

including second-offense operating while intoxicated.1 The child was removed

from the mother’s custody and placed with the paternal grandmother, where she

has remained.2 She was adjudicated as a child in need of assistance in June.

The mother was released from jail in early August and started inpatient

substance-use treatment. She completed treatment the next month and moved in

with the paternal grandmother to begin a trial home placement with the child. But

the placement ended less than a month later when the mother missed multiple

drug tests and failed to follow through with outpatient treatment. From there, the

mother’s housing and participation in treatment were unstable. She was also

ignoring her mental-health needs. By November, the Iowa Department of Health

and Human Services recommended the filing of a termination petition.

There were some bright spots for the mother after the State filed the petition

in mid-November. She had three negative tests for substances later that month

and into December. And she re-engaged in outpatient substance-use treatment,

although her provider noted that “she seemed to be less than interested.” With

this partial progress, the mother’s visits moved to semi-supervised in late

December. But just a few days later, the mother relapsed on alcohol. Around the

1 The mother’s first operating-while-intoxicated offense was from August 2022. 2 The child’s father was in prison when she was removed. 3

same time, she led law enforcement on yet another intoxicated high-speed

chase—at times exceeding 100 miles per hour—before crashing into a cable

barrier. The mother was again charged with several crimes, including another

operating while intoxicated.

At the termination hearing in January 2024, the mother was in jail awaiting

resolution of her many charges. She asked for more time to deal with those

charges and “show that [she] can be a safe and a sober parent.” But she didn’t

know when, or how, the charges would be resolved. The department caseworker

did not support giving the mother additional time, testifying: “[E]very time there’s

maybe one step forward there’s several steps backwards . . . and more time is not

going to change that.”

In its termination ruling, the juvenile court found the evidence sufficient to

support termination of the mother’s parental rights under Iowa Code

section 232.116(1)(g) and (h) (2023).3 The court found termination of the mother’s

rights to be in the child’s best interests because the mother had been given multiple

opportunities at reunification, but she “failed to follow through with most of the

services offered.” Last, the court found that none of the exceptions to termination

applied. With each of the three steps in our termination framework satisfied, the

court terminated the mother’s parental rights.4

3 While the termination ruling at one point said the State’s petition should also be

sustained under Iowa Code section 232.116(1)(l), it later said termination was denied on that ground “given the lack of evidence that [the mother] has a diagnosed severe substance-related disorder.” 4 The father was in prison for most of the proceedings but was paroled roughly one

month before the termination hearing. The juvenile court granted him an additional three months to work toward reunification given his progress while in prison and after his release. 4

The mother now appeals, challenging the sufficiency of evidence supporting

the grounds for termination and arguing termination is contrary to the child’s best

interests due to the closeness of the parent-child bond. We review these claims

de novo. See In re L.B., 970 N.W.2d 311, 313 (Iowa 2022).

Beginning with the grounds for termination, “[w]hen the juvenile court

terminates parental rights on more than one statutory ground, we may affirm the

juvenile court’s order on any ground we find supported by the record.” In re

A.B., 815 N.W.2d 764, 774 (Iowa 2012). Focusing on section 232.116(1)(h), the

mother only challenges the final element, that the child could not be returned to

her custody at the time of the termination hearing. See Iowa Code

§ 232.116(1)(h)(4) (requiring clear and convincing evidence that child cannot be

returned to parental custody “at the present time”); In re D.W., 791

N.W.2d 703, 707 (Iowa 2010) (interpreting the statutory language “at the present

time” to mean “at the time of the termination hearing”). Yet the mother

acknowledged at the termination hearing that the child could not be returned to her

custody because she was incarcerated. This concession amounted to clear and

convincing evidence supporting termination on this ground. See, e.g., In re Z.R.,

No. 21-1290, 2022 WL 1487119, at *3 (Iowa Ct. App. May 11, 2022).

On appeal, the mother tries to sidestep the effect of her incarceration by

contending the child could have been returned to her custody because she “had

an extensive network of relatives to care for [the child] until she made her pretrial

release.” But placing the child in the custody of a relative—where she already was

at the time of the termination hearing—does not equate to placement of the child

in the custody of the mother, as required by the statute. See In re B.F.-C., 5

No. 21-1914, 2022 WL 1100302, at *3 (Iowa Ct. App. Apr. 13, 2022). And we have

often held that a parent’s incarceration prevents a return of custody within the

meaning of the statute. See, e.g., In re E.R., No. 23-2059, 2024 WL 962320, at *2

(Iowa Ct. App. Mar. 6, 2024); In re J.M., No. 23-1018, 2023 WL 5949193, at *2 n.2

(Iowa Ct. App. Sept. 13, 2023); In re L.B., No. 18-1017, 2018 WL 3650370, at *2

(Iowa Ct. App. Aug. 1, 2018).

Next, the mother argues termination is contrary to the child’s best interests,

see Iowa Code § 232.116(2), due to the closeness of the parent-child bond and

detriment resulting from severance, see id. § 232.116(3)(c). Properly considering

these arguments separately by first addressing the child’s best interests, we “give

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

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

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