In the Interest of M.H. and C.H., Minor Children

CourtCourt of Appeals of Iowa
DecidedMay 21, 2025
Docket25-0398
StatusPublished

This text of In the Interest of M.H. and C.H., Minor Children (In the Interest of M.H. and C.H., Minor Children) 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 M.H. and C.H., Minor Children, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-0398 Filed May 21, 2025

IN THE INTEREST OF M.H. and C.H., Minor Children,

D.L., Mother, Appellant,

M.H., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Lynn Poschner, Judge.

The mother and father separately appeal the termination of their parental

rights to their children. AFFIRMED ON BOTH APPEALS.

Cole J. Mayer of Des Moines Juvenile Public Defender, Des Moines, for

appellant mother.

David Barajas of Macro Law, LLP, Des Moines, for appellant father.

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

General, for appellee State.

Erin Romar of Youth Law Center, Des Moines, attorney and guardian ad

litem for minor children.

Considered without oral argument by Buller, P.J., Sandy, J., and Potterfield,

S.J.*

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

(2025). 2

POTTERFIELD, Senior Judge.

The juvenile court terminated the mother’s and father’s parental rights to

C.H. (born in 2021) and M.H. (born in 2016) pursuant to Iowa Code

section 232.116(1)(f) and (h) (2024), respectively.1 The parents separately

appeal. Each concedes the statutory grounds for termination were proved. Both

argue giving them additional time to work toward reunification or, alternatively,

establishing a guardianship is in the children’s best interests rather than

termination of their parental rights.

Our review of termination proceedings is de novo. In re D.G., 704

N.W.2d 454, 457 (Iowa Ct. App. 2005). We recognize each parent has their own

rights to and relationships with the children. See id. at 459 (“[I]n termination of

parental rights proceedings each parent’s parental rights are separate

adjudications, both factually and legally.”). But we also know that at the time of the

termination trial, these parents lived together and remained in a relationship, and

each had the goal to share in co-parenting the children with the other. We cannot

ignore the reality of how these parents’ lives are intermixed when deciding their

respective legal challenges. That said, we jointly address the parents’ respective

claims on appeal.

Additional Time. Each parent concedes that M.H. and C.H. could not be

returned to their custody at the time of the termination trial in January 2025. See

Iowa Code § 232.116(1)(f)(4), (h)(4). They ask for six more months to work toward

1 The father who appealed is M.H.’s biological and legal father and C.H.’s legal

father; when we say “the father,” we refer to him. The parental rights of C.H.’s putative biological father were also terminated; he does not appeal. 3

reunification with the children. Section 232.104(2)(b) controls the court’s ability to

give the parents more time. It requires the parents to show the impediments to

reunification will no longer exist in six months. See In re W.T., 967 N.W.2d 315,

323 (Iowa 2021) (considering section 232.104(2)(b) and placing burden on parent

requesting additional time). And we must also consider whether delaying

permanency for the children to give the parents additional time is in the children’s

best interests. See id. With that in mind, we review the facts from the underlying

child-in-need-of-assistance and termination-of-parental-rights cases.

The children were formally removed from the parents’ custody in

November 2023 after the Iowa Department of Health and Human Services (HHS)

received allegations the mother was using illicit substances while caring for the

children. Both parents submitted to drug testing; the mother tested positive for

methamphetamine while the father tested positive for methamphetamine, cocaine,

THC, and more. Although not every time, the parents continued to test positive for

illegal substances over the next year. And the final test they each took before the

termination trial—sweat patches worn from November 25 to December 9, 2024—

were positive for methamphetamine, amphetamine, and cocaine metabolite. At

the termination trial, the parents attributed several missed drugs tests in December

and January 2025 to the distance between their new home and the testing location,

yet they admitted they failed to tell HHS they were moving to Nebraska. (And

provided several dates over different months for when the move took place.)

Despite the recent drug test results, each parent claimed sobriety at the

termination trial. The mother testified she last used methamphetamine on

November 13, 2024 (nearly two weeks before her sweat patch test started) while 4

the father testified he never used methamphetamine and had not used cocaine

since sometime in 2023. This testimony was not credible.2

It is unclear what, if any, positive progress the parents made toward sobriety

during the nearly fifteen months the children were removed from their custody. We

cannot say an additional six months will remedy the issues preventing

reunification; we agree with the juvenile court that additional time is not warranted.

Guardianship. In the alternative, the parents maintain the juvenile court

should have established a guardianship for the children rather than terminating

their respective parental rights. The court is authorized to establish guardianship

in lieu of termination following a termination hearing. See Iowa Code § 232.117(5)

(authorizing the court to enter an order in accordance with section 232.104 if,

following a termination hearing, “the court does not order the termination of

parental rights but finds that there is clear and convincing evidence that the child

is a child in need of assistance”). Among other things, the court must conclude

that “termination of the parent-child relationship would not be in the best interest

of the child[ren].” Id. § 232.104(4)(a). And, practically speaking, there must be a

named individual who is willing to serve as guardian. See In re M.H., 12

N.W.3d 159, 162–63 (Iowa Ct. App. 2024) (“While the juvenile court seemed to

conclude that a guardianship was not appropriate here, we have not found in the

2 While the juvenile court did not explicitly make these credibility findings, it noted

the mother’s “pattern . . . of minimizing her [substance] use” and cited the parents “history of lack of progress” as a reason it would not grant additional time to work toward reunification. We understand this statement to mean the court did not credit the parents’ claimed sobriety. See In re A.M., 843 N.W.2d 100, 110 (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.” (citation omitted)). 5

record where a guardianship was requested or a possible guardian named.

Without a named option and evidence supporting the choice of a particular person,

we cannot review the factors that are usually considered when determining

whether a guardianship is appropriate in this case.”).

While the mother asked the juvenile court—and now us—to establish a

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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 D.G.
704 N.W.2d 454 (Court of Appeals of Iowa, 2005)

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