In the Interest of L.L., Minor Child

CourtCourt of Appeals of Iowa
DecidedMarch 11, 2026
Docket25-1997
StatusPublished

This text of In the Interest of L.L., Minor Child (In the Interest of L.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 L.L., Minor Child, (iowactapp 2026).

Opinion

IN THE COURT OF APPEALS OF IOWA _______________

No. 25-1997 Filed March 11, 2026 _______________

In the Interest of L.L., Minor Child, O.L., Mother, Appellant. _______________

Appeal from the Iowa District Court for Polk County, The Honorable Susan Cox, Judge. _______________

AFFIRMED _______________

ConGarry Williams, Juvenile Public Defender Office, Des Moines, attorney for appellant mother.

Brenna Bird, Attorney General, and Michelle R. Becker, Assistant Attorney General, attorneys for appellee State.

Lisa A. Allison of Youth Law Center, Des Moines, attorney and guardian ad litem for minor child. _______________

Considered without oral argument by Greer, P.J., and Schumacher and Chicchelly, JJ. Opinion by Greer, P.J.

1 GREER, Presiding Judge.

A mother appeals the termination of her parental rights to one child, arguing that termination is not in the child’s best interests. On our de novo review of the record, we affirm the termination of the mother’s parental rights.

I. Background Facts and Proceedings.

The child, L.L., was born in October 2020 in California.1 In March 2024, the mother and child moved from California to Iowa. The child has been involved with child protective services in both California and Iowa for the majority of his life.

The mother has several mental-health diagnoses, including severe depression and psychosis. On April 18, 2024, the mother was admitted to a psychiatric unit in Council Bluffs, leaving the child without a caretaker. The mother remained hospitalized for ten days. The juvenile court removed the child from mother’s custody and placed the child in the custody of the Iowa Department of Health and Human Services (HHS), which then placed the child in foster care.

After the mother’s discharge from the hospital, she moved to Des Moines to live with her godmother, the child’s fictive kin. The child remained in foster care.

HHS coordinated for the mother to have weekly, in-person visits with the child. The mother repeatedly failed to take advantage of this visitation, often ending visits early. For example, on May 3, the mother opted for a

1 The child’s biological father is unknown. The rights to all putative and unknown fathers were terminated, and that decision has not been appealed.

2 phone visit instead of an in-person visit with the child. The child began to cry when the mother called him, and the mother told the child it was not polite to cry when someone is trying to talk to you. At another visit on May 10, after about an hour, the mother repeatedly asked the child if he was done and wanted to go home. The child began to cry. During another visit, the mother acknowledged the child had been in foster care for a majority of his life, stating, “we are just getting to know each other.”

On May 31, the child was transferred from foster care to the care of the fictive kin. On June 14, the child was adjudicated as a child in need of assistance.2

On July 3, the mother moved out of the fictive kin’s home, opting instead to live in a homeless shelter. The child remained in the fictive kin’s care. A month or so later, the mother obtained her own housing with the assistance of the homeless shelter. She gave birth to another child in mid- October.3

In April 2025, after several issues arose with the fictive kin, the child was removed from the fictive kin’s care and again placed in foster care. The child remained in foster care for the duration of this case.

On April 16, the juvenile court granted the mother an additional six months to work toward reunification. She was ordered to abstain from using substances, participate in random drug screens, and develop a treatment plan with her mental-health provider. Two days later, HHS requested the mother have a sweat patch drug test applied. At a staffing on May 2, the mother

2 Venue of this case was transferred from Pottawattamie County to Polk County in July 2024. 3 This child is the subject of separate juvenile court proceedings.

3 reported the patch had fallen off and she later threw it away. HHS requested the mother have another sweat patch placed, and on May 18, she tested positive for THC, methamphetamine, and cocaine. There continued to be issues with positive drug tests and tampering with sweat patches throughout this matter.

On May 23, the mother ended a visit with the child after forty-five minutes. The mother reportedly wanted to discuss the results of her drug test with the worker, who “redirected [the mother] to focus on her visit with her child[].” The mother failed to provide necessities for the child at this visit and became upset with the worker for not providing items for him.

On July 16, the child was moved from one foster family to another. HHS decided to only inform the mother of the foster parents’ first names due to her repeatedly messaging the former foster parents. This led the mother to file police reports, an Ombudsman’s report claiming that HHS was trafficking her children, and an email to a local news station with the child’s photo attached stating he was missing.

The mother’s cooperation with HHS became an issue, and on July 21, she revoked the releases for her healthcare providers and the child’s healthcare providers, preventing HHS from obtaining details about their treatment. Further, in August, during a visit with the child, the mother told the child to tell the visit supervisor that the HHS social worker had hurt him at a visit. The child was visibly upset. After this incident, visits were reduced to once per week, fully supervised.

On September 8, the State filed a petition to terminate the mother’s rights. The court held a termination hearing on September 24. At the

4 hearing, the HHS social worker and the guardian ad litem (GAL) recommended termination of the mother’s parental rights.

In the GAL’s report to the court, the GAL noted, Visits have been scaled back due to [the child]’s negative behaviors when he returns. He is withdrawn and quiet, similarly to when he was in [the fictive kin]’s care. He also started having “accidents” again after visits, which he had not done in some time. As a result, the Department and the undersigned agreed that the visitation schedule needed to decrease to protect [the child]’s mental health. The decrease in visits has greatly helped reduce those symptoms.

On November 11, the juvenile court entered an order terminating the mother’s parental rights under Iowa Code section 232.116(1)(f ) (2025). In terminating the mother’s parental rights, the court noted that the mother continued to struggle with her mental health, substance use, and safety, which prevented her from parenting the child. Regarding whether termination was in the child’s best interests, the juvenile court concluded: [The child] deserves to have a dedicated caregiver who prioritizes his basic needs and safety. He requires such a caregiver now and in the future. [The child] is approximately five years old and has waited almost his entire life- for a parent to be able to safely care for him. [The mother] cannot safely care for him. Her needs for therapy and treatment and safety are immense. [The mother] deserves all these things, but [the child] has waited and waited for permanency. Given the course of child welfare cases in California, Pottawattamie County and now Polk County, there is no evidence that a parent will be able to provide safety or stability for [the child] in the reasonably foreseeable future. Termination and adoption are in [the child]’s best interest.

Furthermore, the court has considered whether another extension or guardianship would be in [the child]’s best interest or statutorily required. The court does not believe those legal options are in [the child]’s best interest or statutorily required.

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Related

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)

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