In the Interest of O.P., Minor Child

CourtCourt of Appeals of Iowa
DecidedOctober 7, 2020
Docket20-0995
StatusPublished

This text of In the Interest of O.P., Minor Child (In the Interest of O.P., 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 O.P., Minor Child, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0995 Filed October 7, 2020

IN THE INTEREST OF O.P., Minor Child,

R.P., Father, Appellant,

J.V., Mother, Appellant. ________________________________________________________________

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

District Associate Judge.

The mother and father separately appeal the termination of their respective

parental rights to their child. AFFIRMED ON BOTH APPEALS.

Blake D. Lubinus of Lubinus & Merrill, P.L.C. (until withdrawal), Des Moines,

and Marshall Orsini, Des Moines for appellant father.

Cole J. Mayer of Macro & Kozlowski, L.L.P., West Des Moines, for appellant

mother.

Thomas J. Miller, Attorney General, and Meredith L. Lamberti, Assistant

Attorney General, for appellee State.

Paul White of the Juvenile Public Defender’s Office, Des Moines, attorney,

and guardian ad litem for minor child.

Considered by Doyle, P.J., and Mullins and Greer, JJ. 2

GREER, Judge.

The mother and father separately appeal the termination of their respective

parental rights to their child, O.P., born in July 2017. The juvenile court terminated

each parent’s rights under Iowa Code section 232.116(1)(h) (2020). On appeal,

the mother maintains the State failed to prove the statutory ground for termination,

the loss of her rights is not in the child’s best interests, and two exceptions to

termination are applicable and should preclude termination. Alternatively, she

asks for a six-month extension to work on reunification. The father echoes the

mother’s claims and also challenges the court’s March 2020 permanency order,

claiming the court should have delayed permanency and given him a six-month

extension rather than ordering the termination-of-parental-rights petition to be filed.

Our review of termination proceedings is de novo. In re D.G., 704 N.W.2d

454, 457 (Iowa Ct. App. 2005). And our primary concern is the best interests of

the child at issue. Id. Here we combine our analysis where the parents raise the

same or similar claims, but we make our determination about each parent

separately. Id. at 459 (“[I]n termination of parental rights proceedings each

parent’s parental rights are separate adjudications, both factually and legally.”)

Each parent claims the State did not prove termination under section

232.116(1)(h). They concede the first three elements are met but challenge the

fourth, which requires proof the child could not be returned to parental custody at

the time of the termination hearing in July 2020. See Iowa Code § 232.116(1)(h)(4)

(requiring “clear and convincing evidence that at the present time the child cannot

be returned to the custody of the child’s parents as provided in section 232.102”); 3

In re D.W., 791 N.W.2d 703, 707 (Iowa 2010) (interpreting the term “at the present

time” to mean “at the time of the termination hearing”).

Each parent contests the court’s finding that their continued use of

methamphetamine prevented O.P. from being safely returned to their care. The

mother focuses her argument on the fact that she has been consistently involved

in substance-abuse treatment. She argues that if she needed more or different

treatment, it was up to the Iowa Department of Human Services (DHS) or the court

to tell her so before the termination hearing. The father claims that his use of

methamphetamine alone is not enough to show the child could not be safely

returned to his care; he argues there must be a nexus shown between his

continued substance abuse and threat of harm to the child. We are not persuaded

by either of these arguments.

Both parents have a long history of methamphetamine use. The mother,

who was thirty-four years old at the time of the termination hearing, testified she

first used methamphetamine at age nineteen and then began using about monthly

after that. She described her past use as a “recreational, every now and then

thing” at parties. But from age twenty-seven to thirty, she used “once a week.”

Since she met the father around age thirty, she testified they used “very minimal,”

“maybe once a month.” The mother maintained she did not have a substance-

abuse problem, but she continued to test positive for methamphetamine despite

DHS involvement with her family. The mother was also aware she needed to

maintain sobriety so O.P. could be returned to her care. The father, who was forty-

one at the time of the termination hearing, testified he also first tried

methamphetamine in his late teens. He continued to use until age twenty-seven, 4

when his mother died from a methamphetamine overdose. After that, he stopped

using methamphetamine for several years. He admitted he and the mother have

been using together “once, twice a month maybe” since he met her at age thirty-

eight. The father minimized the significance of their decision to continue using

methamphetamine after the birth of their child, testifying, “I mean, it really wasn’t

like we were looking for it every day. We weren’t selling pictures off the wall, selling

TVs or robbing little old ladies at ATMs get a fix.”

The mother’s ongoing participation in substance-abuse counseling, while a

positive thing, is not sufficient to establish that she can safely care for O.P. We

acknowledge the counselor seems encouraged by the mother’s progress, but the

counselor does not independently drug test the mother and relies on the mother’s

self-reports about her sobriety. The mother continues to report to the counselor

(and testified at the termination hearing) that after she completed an extended

outpatient substance-abuse program in August 2019, she used methamphetamine

only once—when she relapsed in October 2019. Yet, she has several drug tests

positive for methamphetamine after her treatment program—testing positive in

October and December 2019 and January and March 2020. The mother’s general

denials of ongoing use of methamphetamine lack credibility, and O.P. could not be

safely returned to her care. See In re M.S., 889 N.W.2d 675, 680 (Iowa Ct. App.

2016) (noting a child cannot be returned to the custody of the parent if doing so

would expose the child to any harm amounting to a new child-in-need-of-

assistance adjudication).

The father argues that his continuing use of methamphetamine does not

mean O.P. cannot be returned to his care. The father cites M.S. in support of his 5

claim. 889 N.W.2d at 682. But that case required the State to establish a nexus

between the parent’s use of cannabis and an appreciable risk of adjudicatory harm.

Id. Our case law distinguishes between use of cannabis and addictions to

methamphetamine. See, e.g., In re J.S., 846 N.W.2d 36, 42 (Iowa 2014) (“[A]

juvenile court could reasonably determine that a parent’s active addiction to

methamphetamine is ‘imminently likely’ to result in harmful effects to the physical,

mental, or social wellbeing of the child[] in the parent’s care.”). And here, the case

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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 M.S., Minor Child, T.B.-w., Father
889 N.W.2d 675 (Court of Appeals of Iowa, 2016)
In The Interest Of D.W., Minor Child, A.M.W., Mother
791 N.W.2d 703 (Supreme Court of Iowa, 2010)
In the Interest of D.G.
704 N.W.2d 454 (Court of Appeals of Iowa, 2005)

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