In the Interest of L.T., Minor Child

CourtCourt of Appeals of Iowa
DecidedJuly 20, 2022
Docket22-0760
StatusPublished

This text of In the Interest of L.T., Minor Child (In the Interest of L.T., 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.T., Minor Child, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0760 Filed July 20, 2022

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

A.R., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, David F. Staudt,

Judge.

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

Andrew C. Abbott of Abbott Law Office, P.C., Waterloo, for appellant

mother.

Thomas J. Miller, Attorney General, and Ellen Ramsey-Kacena, Assistant

Attorney General for appellee State.

Tammy L. Banning of Waterloo Juvenile Public Defender’s Office, Waterloo,

attorney and guardian ad litem for minor child.

Considered by Bower, C.J., and Schumacher and Ahlers, JJ. 2

SCHUMACHER, Judge.

A mother appeals the termination of her parental rights. We find the

termination of the mother’s parental rights is supported by clear and convincing

evidence, termination is in the child’s best interests, and an exception to

termination should not be applied. We affirm the decision of the juvenile court.

I. Background Facts & Proceedings

A.R. is the mother of L.T., who was born in 2021. At the time of the child’s

birth, the mother was involved in services with the Iowa Department of Human

Services (DHS) for an older child, C.R. The mother has a history of mental-health

and substance-abuse concerns.1 The mother tested positive for

methamphetamine at the time of L.T.’s birth. The child also tested positive for

methamphetamine.

The child was removed from the mother’s custody on March 16 and placed

in the care of a maternal aunt. The mother did not have any visits with the child

after the removal until July. On July 16, the child was adjudicated to be in need of

assistance (CINA), under Iowa Code section 232.2(6)(n) and (o) (2021).

In August, the mother reported that she had scabies, which is very

contagious. Her visits were put on hold until she could show the condition had

cleared. The mother did not request visitation during this time. She did not provide

timely information to social workers about her health. The dispositional order,

1 During the juvenile court services for C.R., the mother tested positive for methamphetamine in March 2020. She had a substance-abuse evaluation in May. The mother also had a history of using marijuana and alcohol. The mother had a mental-health evaluation in May as well. She was diagnosed with an adjustment disorder but did not follow through with treatment. 3

dated October 26, noted the mother had not significantly participated in requested

services or random drug testing.

On January 22, 2022, the State filed a petition for termination of the

mother’s parental rights. The mother resumed visitation in early March. In March

2022, DHS received information that the mother was treated for scabies on August

30, 2021. The mother did not provide this information to DHS at the time of

treatment, although she was expressly told that her failure to provide the

information was preventing her from participating in visitation. The mother did not

have visitation with the child from August 2021 to March 2022 because she did not

provide DHS with necessary information about her health.

The termination hearing was held on March 31. Lindsay Brown, a social

worker with DHS, testified the mother did not obtain a substance-abuse evaluation

or receive any treatment during the course of the CINA proceedings. The mother

did not obtain a new mental-health evaluation. The mother was inconsistent in

participating in family-centered services. Brown testified the mother was evasive

with social workers and was “difficult to track in conversation.”

On April 25, the juvenile court terminated the mother’s parental rights under

section 232.116(1)(e) and (h) (2022). The court stated:

[The mother] has failed to participate in substance abuse and mental health treatment. She has elected not to participate in random drug testing. She has failed to maintain her sobriety to the court’s knowledge. She has failed to provide financially for the child in any significant way. She has failed to maintain any significant bond with the minor child. [The mother] has opted to fail to obtain simple medical documentation that would allow her to visit with her child. She was keenly aware of the necessity to do so. [The mother] has also failed to display the appropriate caretaking abilities. 4

The court concluded the child could not be returned to the mother’s care, noting

she was unable to “provide the sober atmosphere necessary for raising a child.”

The court determined termination of the mother’s parental rights was in the child’s

best interests. The mother appeals the juvenile court’s decision.2

II. Standard of Review

Our review of termination proceedings is de novo. In re A.B., 815 N.W.2d

764, 773 (Iowa 2012). The State must prove its allegations for termination by clear

and convincing evidence. In re C.B., 611 N.W.2d 489, 492 (Iowa 2000). “‘Clear

and convincing evidence’ means there are no serious or substantial doubts as to

the correctness [of] conclusions of law drawn from the evidence.” Id. Our primary

concern is the best interests of the child. In re J.S., 846 N.W.2d 36, 40 (Iowa

2014).

III. Discussion

We follow a three-step analysis in reviewing the termination of a parent’s

rights. In re P.L., 778 N.W.2d 33, 39 (Iowa 2010). We first consider whether there

is a statutory ground for termination of the parent’s rights under section 232.116(1).

Id. Second, we look to whether termination of the parent’s rights is in the child’s

best interests. Id. (citing Iowa Code § 232.116(2)). Third, we consider whether

any of the exceptions to termination in section 232.116(3) should be applied. Id.

A. Sufficiency of the Evidence

On the first issue, sufficiency of the evidence, “[w]e will uphold an order

terminating parental rights where there is clear and convincing evidence of the

2 The father’s parental rights were also terminated. He has not appealed. 5

statutory grounds for termination.” In re T.S., 868 N.W.2d 425, 434 (Iowa Ct. App.

2015). “When the juvenile court orders termination of parental rights on more than

one statutory ground, we need only find grounds to terminate on one of the

sections to affirm.” Id. at 435. We consider the termination of the mother’s parental

rights under section 232.116(1)(h).3

The mother disputes only the fourth element of section 232.116(1)(h). She

asserts that she was willing and able to take the child into her care at the time of

the termination. In re A.M., 843 N.W.2d 100, 111 (Iowa 2014) (noting we consider

whether a child can be returned to the parent’s care at the time of the termination

hearing).

The mother has not addressed the issues that caused the child’s removal

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

Related

In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
In the Interest of J.S. & N.S., Minor Children, A.S., Mother
846 N.W.2d 36 (Supreme Court of Iowa, 2014)
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 A.B. & S.B., Minor Children, S.B., Father
815 N.W.2d 764 (Supreme Court of Iowa, 2012)
In the Interest of A.R. and A.R., Minor Children
932 N.W.2d 588 (Court of Appeals of Iowa, 2019)
In the Interest of C.B.
611 N.W.2d 489 (Supreme Court of Iowa, 2000)
In the Interest of D.S.
806 N.W.2d 458 (Court of Appeals of Iowa, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of L.T., Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-lt-minor-child-iowactapp-2022.