In the Interest of N.M., Minor Child

CourtCourt of Appeals of Iowa
DecidedSeptember 23, 2020
Docket20-0882
StatusPublished

This text of In the Interest of N.M., Minor Child (In the Interest of N.M., 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.M., Minor Child, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0882 Filed September 23, 2020

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

M.T., Mother, Appellant,

K.M., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Mahaska County, Rose Anne

Mefford, District Associate Judge.

The mother and biological father of the child separately appeal the

termination of their parental rights. AFFIRMED ON BOTH APPEALS.

Eric J. Palmer of Palmer Law Office, Oskaloosa, for appellant mother.

Patrick J. Mahaffey of Mahaffey Law Office, Montezuma, for appellant

father.

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

Attorney General, for appellee State.

Denise McKelvie Gonyea, Grinnell, attorney and guardian ad litem for minor

child.

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

AHLERS, Judge.

N.M. was born in January 2019 and removed from the parents’ care at the

age of three months. Prior to removal, the child had been dropped at least twice,

deprived of food to the point of being re-hospitalized, and otherwise largely ignored

by the parents. Fast-forwarding approximately nine months after removal to the

termination-of-parental-rights hearing, the child had never been returned to the

care of the parents and the parents had not progressed past supervised visits. The

juvenile court terminated the parental rights of the mother, the biological father,

and the legally established father (the mother’s husband). Only the mother and

biological father appeal.1

Our review of a termination-of-parental-rights proceeding is de novo. In re

A.S., 906 N.W.2d 467, 472 (Iowa 2018). On de novo review, we are not bound by

the juvenile court’s factual findings, but we ‘give them weight, especially in

assessing the credibility of witnesses.’” Id. (quoting In re A.M., 843 N.W.2d 100,

110 (Iowa 2014)).

Review of termination-of-parental-rights proceedings under Iowa Code

chapter 232 (2019) follows a three-step analysis: (1) determine whether any

ground for termination under section 232.116(1) has been established; (2)

determine whether the best-interest-of-the-child framework set forth in section

232.116(2) supports termination of parental rights; and (3) “consider whether any

1 Because the legally established father did not appeal, we have little need to address him in this opinion. When we refer to “the parents” in this ruling, we are referring to the mother and the biological father. When we refer to the legally- established father, we refer to him as such. 3

exceptions in section 232.116(3) apply to preclude termination of parental rights.”

In re M.W., 876 N.W.2d 212, 219–20 (Iowa 2016).

From what we can glean from the petitions on appeal,2 the parents are

challenging one element of the statutory grounds for termination (step 1) and the

determination that termination is in the child’s best interest (step 2). To the extent

any other challenges were intended to be asserted, we deem the issues waived

for failure to adequately identify or argue the issues. See Soo Line R.R. Co. v.

Iowa Dep’t of Transp., 521 N.W.2d 685, 691 (Iowa 1994) (holding “random mention

of an issue, without elaboration or supportive authority, is insufficient to raise the

issue for” appellate consideration); see also In re C.B., 611 N.W.2d 489, 492 (Iowa

2000) (“A broad, all encompassing argument is insufficient to identify error in cases

of de novo review.”).

The parental rights of both parents were terminated pursuant to Iowa Code

section 232.116(1)(h), which requires proof of the following:

(1) The child is three years of age or younger. (2) The child has been adjudicated a child in need of assistance pursuant to section 232.96. (3) The child has been removed from the physical custody of the child’s parents for at least six months of the last twelve months,

2 We express some uncertainty as to the issues presented because of the nature of the petitions filed. Each petition listed only one issue. However, either in the heading identifying the issue or in the body of the argument that followed, each party blended multiple concepts, causing uncertainty as to the issues the party desired us to address. We recognize the expedited time deadlines and truncated procedures for appeals in termination-of-parental-rights cases create challenges for the attorneys. See In re C.M., 652 N.W.2d 204, 208–09 (Iowa 2002) (discussing the expedited procedure for termination appeals). We endeavor to accommodate the attorneys in light of those challenges by giving them the benefit of the doubt when determining the issues presented. Nevertheless, it would assist us, and decrease the likelihood of a misunderstanding as to the issues presented, if an appealing party separately identified and argued each issue presented, even if additionally identified issues involve arguing many of the same facts. 4

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 the child cannot be returned to the custody of the child’s parents as provided in section 232.102 at the present time.

The parents challenge only the fourth element, claiming the child could have

been returned to their care at the time of the termination hearing. See In re D.W.,

791 N.W.2d 703, 707 (Iowa 2010) (interpreting the statutory language “at the

present time” to mean “at the time of the termination hearing”). However, neither

parent points to any evidence that supports their claims. Instead, they argue they

have been making some progress, are participating in most of the services offered,

and should have been given more time to succeed. Consistent with their blending

of issues in their petitions on appeal as mentioned earlier, this appears to be a

blending of the arguments on the statutory grounds and best-interest issues.

As to the statutory grounds issue, the parents’ argument does not advance

their cause. Whether the parents were making progress or could have succeeded

at some future time does not negate the juvenile court’s determination that the

child could not be returned to the care of either parent at the time of the termination

hearing. In fact, it is an acknowledgment of the correctness of the juvenile court’s

finding. On our de novo review, we agree with the juvenile court that the child

could not be returned to either parent at the time of the termination hearing, so the

statutory grounds for termination were satisfied.

Turning to each parent’s argument that termination of their respective rights

is not in the child’s best interest, we consider the parents’ claims that they had

done much of what had been asked of them and had made some progress,

transportation issues caused by their lack of means formed the primary reason for 5

their shortcomings, and it is not in the child’s best interest to “rush” termination.

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