In the Interest of K.F., Minor Child

CourtCourt of Appeals of Iowa
DecidedJuly 24, 2024
Docket24-0423
StatusPublished

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

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0423 Filed July 24, 2024

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

A.F., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Marshall County, Paul J. Crawford,

Judge.

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

Norma J. Meade of Moore, McKibben, Goodman & Lorenz, LLP,

Marshalltown, for appellant mother.

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

General, for appellee State.

Mary Cowdrey of Public Defender’s Office, Marshalltown, attorney and

guardian ad litem for minor child.

Considered by Chicchelly, P.J., Buller, J., and Blane, S.J.*

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

(2024). 2

BLANE, Senior Judge.

A mother appeals the termination of her parental rights to her not yet two-

year-old child. She contends the State failed to prove the statutory ground for

termination and failed to make reasonable efforts in her case. We find no merit in

either claim, so we affirm.

I. Background facts and proceedings

This case began in March 2023 when the Department of Health and Human

Services investigated the maternal grandmother for allegations of drug use while

caring for her teenage daughter. The mother and her child, K.F., also lived with

the maternal grandmother at the time, and further allegations arose that the mother

was using drugs while caring for K.F. The mother admitted to using

methamphetamine and agreed to a voluntary placement of K.F. with a foster

family.1

Since then, the mother has struggled to engage in services to treat her

substance-use issues. A substance-use evaluation recommended that she attend

outpatient treatment groups until space became available in a residential treatment

facility. The mother did not attend the outpatient program consistently. In June,

the mother entered an inpatient program but left the next day complaining that

orientation overwhelmed her. The next month she started outpatient treatment

again but did not attend consistently. In October she began outpatient treatment

again but this time withdrew a previous informational release so the department

could not track her progress. That same month she overdosed on heroin and was

1 The putative father of K.F. had minimal involvement in the case. The juvenile court terminated his parental rights, and he does not appeal. 3

treated at the hospital. In December, she entered a thirty-day residential treatment

facility and was successfully discharged. But providers reported her participation

wasn’t consistent while she was there. Within days of completion, she used

methamphetamine again. The mother also gave many positive drug tests or failed

to appear for drug tests throughout the proceedings.

Her attendance and performance at visitation were also inconsistent, and

were exacerbated when the mother committed felony probation violations, and had

multiple arrests and stints in jail. Providers and the foster parents reported the

mother appeared intoxicated during some in-person and video visits. And the

department suspended her visits while she had active warrants out for her arrest.

The State petitioned for termination of the mother’s parental rights in

December 2023. The court held a joint permanency and termination-of-parental-

rights hearing in February 2024. At the hearing, it was established the mother had

admitted recently using methamphetamine on January 26 and 28, and she testified

to last using methamphetamine three days before the hearing. The juvenile court

found grounds for termination were supported under Iowa Code section

232.116(1)(h) (2023). The mother appeals.

II. Standard of review

We review termination proceedings de novo. In re L.B., 970 N.W.2d 311,

313 (Iowa 2022). We respect the juvenile court’s fact findings, especially when

they rest on witness credibility. In re R.K.B., 572 N.W.2d 600, 601 (Iowa 1998).

But we are not bound by them. Id. Our primary concern is the best interests of

the child. Id. 4

III. Analysis

Termination requires clear and convincing evidence of three analytical

steps. See In re D.W., 791 N.W.2d 703, 706–07 (Iowa 2010). We determine

whether termination is warranted under statutory grounds, if termination is in the

child’s best interests, and if a statutory exception applies to preclude termination.

In re L.B., 970 N.W.2d 311, 313 (Iowa 2022). On appeal, we need not address

any step the parent does not challenge. See In re P.L., 778 N.W.2d 33, 40 (Iowa

2010).

A. Statutory Grounds for Termination

The court terminated the mother’s parental rights under Iowa Code section

232.116(1)(h).2 She contends the State failed to show that K.F. could not be

returned to her custody at the time of the hearing. See Iowa Code § 232.116(h)(4);

see also In re M.W., 876 N.W.2d 212, 219 (Iowa 2016) (requiring proof of statutory

grounds by clear and convincing evidence). She argues that because she was

about to return to an inpatient treatment program that allows children to be placed

2 To find termination appropriate under paragraph (h), the court must find all the

following supported by clear and convincing evidence: (1) The child is three years of age or younger. (2) The child has been adjudicated a child in need of assistance pursuant to section 232.96. (3) The child has been removed from the physical custody of the child’s parents for at least six months of the last twelve months, or for the last six consecutive months and any trial period at home has been less than thirty days. (4) There is clear and convincing evidence that the child cannot be returned to the custody of the child's parents as provided in section 232.102 at the present time. Iowa Code § 232.116(1)(h). 5

with their parents, the State didn’t prove the child could not be returned to her

custody.

We disagree. At the termination hearing, the mother was not in the

treatment program, she was waiting for admission, so she could not resume

custody “at the present time,” as the statute requires. Iowa Code § 232.116(h)(4);

see In re A.S., 906 N.W.2d 467, 474 (Iowa 2018) (holding “at the present time” in

Iowa Code § 232.116(1)(h)(4) to mean the time of the termination hearing). And

placing a child with a parent in a supervised treatment program is different from

the parent resuming legal custody of the child.3 The mother was still actively

addicted to drugs and had used methamphetamine just days before the

termination trial.

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Related

In Interest of RKB
572 N.W.2d 600 (Supreme Court of Iowa, 1998)
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