In the Interest of N.H., Minor Child

CourtCourt of Appeals of Iowa
DecidedJune 18, 2025
Docket25-0292
StatusPublished

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

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

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-0292 Filed June 18, 2025

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

J.H., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Kimberly Ayotte, Judge.

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

Zachary C. Priebe of Jeff Carter Law Offices, PC, Des Moines, for appellant

father.

Brenna Bird, Attorney General, and Mackenzie Moran, Assistant Attorney

General, for appellee State.

Shannon Wallace, Des Moines, attorney and guardian ad litem for minor

child.

Considered without oral argument by Tabor, C.J., and Ahlers and Langholz,

JJ. 2

TABOR, Chief Judge.

A father, James, appeals the juvenile court order terminating his parental

rights to his son, N.H., born in 2023. He challenges the statutory grounds for

termination and contends that the juvenile court should have returned N.H. to his

custody or granted his request for a six-month extension to achieve reunification.

Alternatively, he claims that it would be in N.H.’s best interests to establish a

guardianship rather than terminating parental rights. After carefully considering

the record, we affirm the termination order.1

I. Facts and Prior Proceedings

N.H. came to the attention of the Iowa Department of Health and Human

Services in February 2024 after being treated for a skull fracture at Blank

Children’s Hospital. He was nine months old at that time. The treating physician

reported to the department and police that the child’s injury was likely caused by

nonaccidental trauma. Department workers and police detectives determined that

N.H. was in his mother’s care when he was injured. They also discovered video

of the mother hitting, kicking, and grabbing the infant. The State charged the

mother with felony child endangerment.2 In late February, the juvenile court

ordered N.H.’s removal from parental custody. The department placed him with

his maternal aunt, where he has remained since. The court adjudicated N.H. as a

child in need of assistance (CINA) in April 2024.

1 Our review is de novo. In re M.H., 12 N.W.3d 159, 160 (Iowa Ct. App. 2024). We examine the entire record, finding our own facts and adjudicating rights anew on issues properly before us. Id. But we respect the juvenile court’s factual findings, especially on credibility issues. Id. 2 The mother pleaded guilty but denied injuring N.H. when she testified at the

termination hearing. She is serving a seven-year prison sentence. 3

Paternity testing confirmed that James is N.H.’s father. The department

offered James weekly supervised visits with N.H. at the beginning of the CINA

case. He ended at least one visit early, cancelled several others, and did not bring

supplies for N.H. to the visits he attended. The department referred him to

SafeCare services, but he was discharged in May 2024 for noncompliance. The

department also asked him to provide drug screens in May and July 2024, but he

did not comply with those requests.3

Meanwhile, James was arrested for possession of methamphetamine in

June 2024. Then in July, he had an active arrest warrant for felony domestic abuse

assault.4 After learning of that warrant, the department suspended James’s visits

with N.H. The department could not locate James from July 2024 until his arrest

in October. James remained in jail until January 2025, when he pleaded guilty to

the domestic abuse assault and the court placed him on probation. After his

release from jail, he did not contact the department to request visits with N.H. until

a few days before the termination hearing. The department denied his request.5

The State petitioned to terminate parental rights. James and the mother

testified at the termination hearing. James explained that his relationship with the

mother ended while she was pregnant with N.H. When asked about his history of

substance use, he admitted that he started using marijuana during high school and

methamphetamine in 2018. According to his testimony, he “quit using daily” when

3 The department noted in its termination report to the court that those “missed

drug screens will be considered positive.” 4 The victim of that assault reported to police that James strangled her until she

lost consciousness. 5 James has not seen N.H. since July 2024. 4

N.H. was born but “relapsed and started using” again several times per day after

N.H.’s removal. He acknowledged that the department offered him resources for

a substance-use evaluation, but he neither had that evaluation nor participated in

substance-use treatment. He completed a mental-health evaluation and received

medication for depression, but he had not started recommended therapy. Nor had

he started the Iowa Domestic Abuse Program—a condition of his probation.

James also testified that he lived with his father’s ex-girlfriend in her trailer.

She paid for rent, utilities, and groceries. He did not have a job or transportation

of his own. But he said he planned to look for employment and save to regain his

driver’s license so that he could support himself. He believed it “could take up to

six months to a year” to obtain his license and housing. As his bottom line, James

asked the court to return N.H. to his custody or grant a six-month extension.

The department caseworker recommended termination, emphasizing that

James “hasn’t participated meaningfully in services or engaged meaningfully in

interactions with [N.H.].” The guardian ad litem (GAL) also supported termination.

She acknowledged that James was “trying” but urged that “he does not have things

in place right now where he could successfully take [N.H.] or support him.”

The juvenile court denied James’s request for an extension and terminated

N.H.’s legal relationship with both parents. Only James appeals.

II. Analysis

The juvenile court terminated James’s parental rights under Iowa Code

section 232.116(1), paragraphs (b), (d), (e), and (h) (2025). James disputes those

grounds for termination and asks for six more months to achieve reunification.

Alternatively, he claims that establishing a guardianship rather than terminating his 5

parental rights would better serve N.H.’s best interests. We will address each of

those claims in turn.

A. Statutory Ground for Termination

When the juvenile court relies on more than one statutory ground for

termination, we may affirm “on any ground . . . supported by the record.” In re A.B.,

815 N.W.2d 764, 774 (Iowa 2012). We rest our decision on paragraph (h).

The juvenile court could terminate parental rights on that ground if the State

offered clear and convincing evidence of these elements:

(1) [N.H.] is three years of age or younger. (2) [N.H.] has been adjudicated a child in need of assistance pursuant to section 232.96. (3) [N.H.] has been removed from the physical custody of [his] parents for at least six months of the last twelve months, or for the last six consecutive months and any trial period at home has been less than thirty days. (4) There is clear and convincing evidence that [N.H.] cannot be returned to the custody of [his] parents as provided in section 232.102 at the present time.

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Related

In the Interest of M.S.
519 N.W.2d 398 (Supreme Court of Iowa, 1994)
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 D.W., Minor Child, A.M.W., Mother
791 N.W.2d 703 (Supreme Court of Iowa, 2010)

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