In the Interest of L.H., Minor Child

CourtCourt of Appeals of Iowa
DecidedJanuary 9, 2025
Docket24-1791
StatusPublished

This text of In the Interest of L.H., Minor Child (In the Interest of L.H., 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.

Bluebook
In the Interest of L.H., Minor Child, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1791 Filed January 9, 2025

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

S.O., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Linn County, Carrie K. Bryner,

Judge.

A father appeals the termination of his parental rights. AFFIRMED.

Michael M. Lindeman of Lindeman Law, Cedar Rapids, for appellant father.

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

General, for appellee State.

Rebecca Williams, Cedar Rapids, attorney and guardian ad litem for minor

child.

Considered by Tabor, C.J., and Ahlers and Sandy, JJ. 2

SANDY, Judge.

The juvenile court terminated a father’s parental rights to his minor son

pursuant to Iowa Code section 232.116(1)(e), (g), and (h) (2024). On appeal, the

father challenges one of the statutory grounds for termination. He also contends

termination is not in the child’s best interests and that he should have been granted

a six-month extension to work towards reunification. After our de novo review of

the record, we affirm.

I. Background Facts and Proceeding Facts

L.H. is the child who is the subject of this appeal. He was born in

March 2024. L.H.’s birth brought his mother and father to the attention of the Iowa

Department of Health and Human Services (HHS) because he tested positive for

methamphetamine, amphetamine, and THC. HHS was already familiar with the

mother and father because they had previously been involved in a child-in-need-

of-assistance case (CINA) with L.H.’s older sister.1 A day after his birth, L.H. was

removed from his parents’ custody. On March 27, he was adjudicated in need of

assistance and placed in the custody of HHS for purposes of foster family care.

L.H. was subsequently placed with a foster mother, who already had custody of

his older sister.

Throughout the underlying CINA case and termination proceedings, HHS

has expressed concerns over the father’s history of problems with domestic abuse,

substance use, and mental health. The record reveals the mother and father’s

relationship has been marred by several incidents of domestic abuse, which led to

1 The father’s parental rights to L.H.’s older sister were terminated on June 7, 2024. 3

the mother receiving a no-contact order. HHS asserts numerous violations of the

no-contact order occurred during this case.

The father also has an extensive history of substance-use issues. He has

admitted to regularly using methamphetamine since he was in middle school. As

he told an HHS employee, “You drink coffee, I smoke meth.” Additionally, on

several occasions the father expressed to HHS that he believed the odds of him

ever achieving sobriety were slim. According to him, his odds of achieving sobriety

were low because “only two percent of people actually recover.” He has also

displayed a general hostility toward substance-use treatment programs, asserting

“if he cannot get sober on his own in his own environment then he never will.”

As for his history with mental health struggles, the father told an HHS case

worker he has been “traumatized since birth” and “angry his whole life.” According

to him, he was diagnosed as a child with attention-deficit/hyperactivity disorder

(ADHD), depression, and anxiety. He has acknowledged that his mental health

needs to be addressed because it affects his substance use. During one

interaction with an HHS case manager, it was reported that he stated “he is not

suicidal, it’s more homicidal.”

Despite being offered a litany of services by HHS, the father made

“essentially no progress.” Although HHS had concerns over the father’s history of

domestic abuse, it never offered him services in this case to address those

concerns. This was because the father had previously engaged in some services

to address his domestic abuse issues in the CINA and termination case involving

L.H.’s older sister, which overlapped slightly with this case. The father testified at

the termination hearing that the services he previously engaged in for domestic 4

abuse helped him learn to better control himself. However, the father displayed

an inability to control his anger during this case. After sending several hostile and

threatening text messages to the HHS case manager—a communication plan had

to be implemented between the father and the case manager.

At best, the father made minimal efforts to address his mental health. As

the case manager explained during the termination hearing, HHS had no records

of the father making any attempts to address his mental health. However, the

father testified that he had recently started attending therapy. He also added he

had recently started a medication regiment to help manage his mental-health

issues.2 But he did not provide any information on those efforts to HHS or the

juvenile court.

The father also did not make meaningful progress in addressing his

substance-use issues. The father completed a substance use evaluation in May

2024, which recommended inpatient treatment. On May 29, the father checked

himself into an inpatient treatment facility. But he was unsuccessfully discharged

from the treatment program after leaving the facility after two days. Additionally,

the father never drug tested with HHS, despite thirty-eight requests to do so.3

Throughout this case, the father admitted to regularly using methamphetamine.

During the termination hearing, he testified to using methamphetamine just a few

2 For additional context, the termination hearing was held on October 21, 2024.

The father testified that he finally began efforts to address his mental health in either “September or late August” of 2024. 3 We highlight the father was also required to drug test as a part of his probation

for a criminal charge during this same period. The father has a lengthy criminal history, and he even committed additional criminal offenses during the pendency of this case. Despite being required to drug test, the father did not complete a drug test as a part of his probation after March 2024. 5

weeks earlier.4 Due to his failure to address HHS’s well-documented concerns,

the father never progressed beyond fully supervised visits with L.H.

The juvenile court terminated the father’s parental rights pursuant to Iowa

Code section 232.116(1)(e), (g), and (h). This appeal followed.5

II. Standard of Review

Our review of termination of parental rights proceedings is de novo. In re

J.C., 857 N.W.2d 495, 500 (Iowa 2014). “We are not bound by the juvenile court’s

findings of fact, but we do give them weight, especially in assessing the credibility

of witnesses.” In re C.Z., 956 N.W.2d 113, 120 (Iowa 2021) (citation omitted). “As

always, our fundamental concern is the child’s best interests.” J.C., 857 N.W.2d

at 500.

III. Analysis

We utilize a three-step analysis to review termination of parental rights. In

re M.W., 876 N.W.2d 212, 219 (Iowa 2016). We first consider whether any ground

for termination under section 232.116(1) has been established. Id. If we find a

Free access — add to your briefcase to read the full text and ask questions with AI

Related

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 J.c, Minor Child. D.C., Father
857 N.W.2d 495 (Supreme Court of Iowa, 2014)
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)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of L.H., Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-lh-minor-child-iowactapp-2025.