In the Interest of L.R., Minor Child

CourtCourt of Appeals of Iowa
DecidedMarch 19, 2025
Docket25-0042
StatusPublished

This text of In the Interest of L.R., Minor Child (In the Interest of L.R., 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.R., Minor Child, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-0042 Filed March 19, 2025

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

H.C., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, Korie Talkington,

Judge.

A father appeals the termination of his parental rights to his son.

AFFIRMED.

Paige E. Hillyer, Davenport, for appellant father.

Brenna Bird, Attorney General, and Lisa Jeanes, Assistant Attorney

General, for appellee State.

Steven W. Stickle of Stickle Law Firm, P.L.C., Davenport, attorney and

guardian ad litem for minor child.

Considered by Greer, P.J., and Langholz and Sandy, JJ. 2

LANGHOLZ, Judge.

A son was born while both his parents were incarcerated. So he spent the

next fifteen months in the care of his cousin. By the time his father was released

from prison, the Iowa Department of Health and Human Services believed the time

had come for permanency. And so, the State petitioned to terminate the father’s

parental rights about two weeks after his release.

In the few months between his release and the final termination hearing, the

father tried to show he could care for the son. But although he secured housing

and full-time employment, he participated in no Department-supervised visits with

the son during the month leading up to the final termination hearing. Instead, he

chose to only visit his son for an hour or two while the cousin supervised,

preventing the Department from observing the father’s parenting. What’s more,

he continued to use marijuana, despite having a history of substance use and

never completing treatment. Because the son was now eighteen months old and

the evidence showed the father could not safely care for the son, the juvenile court

terminated the father’s parental rights.

The father appeals, arguing that termination is not in the son’s best interest

and the bond exception should preclude termination. Yet while the son and his

father do share a bond, the son is also very much bonded with his cousin. And the

son’s limited visits with his father over four months have not led to a bond so strong

that would render termination detrimental. Nor is a guardianship a preferable

alternative for the son, who has been out of his father’s care for his entire life and

has found stability with his cousin. Thus, termination of the father’s parental rights

is in the son’s best interest and the bond exception does not preclude termination. 3

I. Factual Background and Proceedings

When the son was born in May 2023, both his mother and father were

incarcerated.1 The Department implemented a safety plan that placed the son in

the care of his maternal cousin. In August, the son was adjudicated in need of

assistance and formally placed in his cousin’s custody. At the time of adjudication,

the son’s father was not yet known. Two months later, paternity testing confirmed

that the appellant here is the son’s father.

The father has a lengthy criminal history. This most recent incarceration

stemmed from second-degree burglary and domestic abuse assault convictions in

2018 and later violations of his probation by committing additional offenses,

including eluding, second-degree criminal mischief, and operating while

intoxicated. After learning he was the son’s father, he began having virtual and

phone conversations with the son from prison. He also participated in parenting

courses.

The father remained in prison until August 2024, when the son was nearly

fifteen months old. Given the son’s prolonged period without a parent present in

his life, the State petitioned to terminate the father’s rights about two weeks after

the father’s release.2 And a termination hearing was scheduled across two days—

the first in late November and another about a month later in December.

1 We avoid using the parties’ names to respect their privacy because this opinion—

unlike the juvenile court’s order—is public. Compare Iowa Code § 232.147(2) (2024), with id. §§ 602.4301(2), 602.5110. 2 The mother remained incarcerated throughout these proceedings and also had

her parental rights terminated. Because she does not appeal, we focus on the father. 4

Upon release, the father split his time between living with his dad 3 and his

girlfriend, who had a history of substance-related criminal convictions. As for his

own substance use, the father acknowledged using illegal substances more than

ten years ago but insisted he was now “clean.” Yet the father regularly used

marijuana after his release and never produced a negative drug test to the

Department. Indeed, while the father acknowledged he used to “fall back” on

“doing drugs”—specifically heroin and methamphetamine—when things got hard,

he has never participated in substance-use treatment.

As for the son, the father began visiting the son soon after his release

without informing the Department. The Department later instructed that visits need

to be supervised and offered the father two Department-supervised visits with the

son each week, with the option of additional visits supervised by the cousin if she

agreed. While the father at first participated in visits, he did not have any

Department-supervised visits with the son in the month between the first and

second days of the termination hearing. Instead, he only arranged visits through

the son’s cousin—lasting an hour or two—which kept the Department from

observing the father care for the son in the weeks just before the final termination

hearing. To that end, the father testified that he did not believe his visits needed

to be supervised, as he’s “never hurt anyone” and “never been in trouble with drugs

or any of that.”

3 The father had four other children and his parental rights to each child was terminated in prior proceedings. The father’s dad has since adopted those children. 5

After the two-day hearing, the juvenile court terminated the father’s parental

rights under paragraphs “e,” “h,” and “l” of Iowa Code section 232.116(1) (2024).

The court emphasized the father’s failure to participate in supervised visits, his

ongoing substance use, his lack of mental-health or substance-use treatment, and

his reluctance to accept “the harm his life choices” have caused the son. The court

also found that terminating the father’s rights, rather than imposing a guardianship,

best served the son, as he “is in need of permanency and should not have to wait

any longer.” And the court declined to apply any statutory exceptions to

termination, finding the need for permanency outweighed the relative-custody

exception and the child’s four-month relationship with the father has not produced

a bond “so strong as to make termination detrimental.”

The father now appeals, challenging the juvenile court’s best-interest and

bond-exception rulings.4

II. The Son’s Best Interest

The State carries the burden to prove by clear and convincing evidence that

terminating the father’s parental rights is in the son’s best interest. See Iowa Code

§ 232.116(2). When weighing the son’s best interest, we “give primary

4 In his petition on appeal, the father summarily mentions that the “State did not

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Related

In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
In the Interest of N.F.
579 N.W.2d 338 (Court of Appeals of Iowa, 1998)
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 A.B. & S.B., Minor Children, S.B., Father
815 N.W.2d 764 (Supreme Court of Iowa, 2012)

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