In the Interest of O.P., Minor Child

CourtCourt of Appeals of Iowa
DecidedMay 24, 2023
Docket23-0464
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 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0464 Filed May 24, 2023

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

J.B., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Carroll County, Joseph B.

McCarville, District Associate Judge.

A mother challenges the juvenile court’s removal order. AFFIRMED.

Mark J. Rasmussen of Rasmussen Law Office, Jefferson, for appellant

mother.

Brenna Bird, Attorney General, and Mary A. Triick, Assistant Attorney

General, for appellee State.

Kaitlyn C. DiMaria of DiMaria Law P.L.L.C., Des Moines, attorney and

guardian ad litem for minor child.

Considered by Bower, C.J., and Tabor and Greer, JJ. 2

GREER, Judge.

In early October 2022, the Iowa Department of Health and Human Services

received allegations that the mother was smoking marijuana in the presence of the

child, born in June 2017. As the department was conducting its initial investigation,

the mother was arrested after she pointed a gun at a woman through her vehicle’s

passenger window and sunroof while the child was in the car. The mother was

arrested in her home, and the police report from the arrest, given to one of the

department’s child protection workers, stated that police found marijuana on the

mother’s dresser and a loaded handgun in the mother’s jacket pocket, which was

laying on the floor. A founded child abuse assessment was completed, noting

concerns with both the mother’s displaying a weapon in front of the child as well

as leaving the gun and marijuana within the child’s reach.

After the mother was arrested, the child was removed from the mother’s

custody and placed in the temporary custody of the department. The county

attorney filed a petition to adjudicate the child in need of assistance (CINA). While

still in jail, the mother called the department social worker and said the child had a

phone and asked the worker to make sure the child had it during their separation.

When the social worker eventually took possession of the phone, there were

obscene photographs of male and female genitalia accessible on the phone; a

second founded child abuse assessment followed, finding the mother allowed the

child access to obscene materials.

The mother was released from jail on November 10. After her release, she

exercised visitation and completed a mental-health evaluation. She also provided 3

a drug screen, which was positive for hydrocodone; it was unclear whether this

medication had been prescribed.1

The child was adjudicated CINA in January 2023, at which time the juvenile

court found the child had “suffered or [was] imminently likely to suffer harmful

effects as a result of . . . the failure of the child’s parent . . . to exercise a reasonable

degree of care in supervising the child.” Iowa Code § 232.96A(3)(b) (Supp. 2022).

That same month, the child’s maternal grandmother moved in with the mother, and

the child was placed in the grandmother’s care; the implemented safety plan stated

all interactions between the mother and child were to be supervised by the

grandmother. Temporary custody of the child remained with the department.

In February, the mother revoked all releases of information2 to the

department and stopped drug testing.3 She had only limited contact with the

department’s social worker, and at the March dispositional hearing, the social

worker could not confirm that the mother was working or making other progress

toward reunification. At the dispositional hearing, the mother asked for the child to

be placed back in her care and custody. The juvenile court instead maintained the

adjudication and placed the child in the department’s custody; with the safety plan

1 The department requested proof of a prescription, but we have no record showing compliance. 2 At the dispositional hearing, the mother claimed she had only revoked the release

for her past medical history. The department’s report to the court ahead of the hearing explained the social worker received a text message from the mother stating, “Do not get any of my releases of info I do not authorize you to get any MORE of my information.” The department treated this as a blanket revocation, and the juvenile court agreed with that characterization. 3 Between the initial CINA adjudication hearing and the dispositional hearing, the

department social worker asked the mother to complete a drug test four times, all of which the mother refused. 4

that the child remain in the grandmother’s care and the grandmother supervise all

interactions between the child and mother. The mother now appeals.

The mother makes two arguments—(1) the child should have been returned

to her custody when she was released from jail, and (2) the child should have been

placed in the mother’s custody at the March dispositional hearing. Her first claim,

however, is moot—once there was a dispositional hearing, “any error committed

in granting the temporary ex parte order cannot now be remedied. We cannot go

back in time and restore custody based on alleged errors in the initial removal

order.” In re A.M.H., 516 N.W.2d 867, 871 (Iowa 1994); see also In re B.B., 826

N.W.2d 425, 428 (Iowa 2013) (“Ordinarily, an appeal is moot if the ‘issue becomes

nonexistent or academic and, consequently, no longer involves a justiciable

controversy.’” (citation omitted)); In re D.N., No. 22-1262, 2023 WL 386705, at *2

(Iowa Ct. App. Jan. 25, 2023) (deeming a mother’s claim about “issues relating to

the initial temporary removal order [were] moot” after the dispositional order

confirming the removal order was entered). So, we turn to the mother’s second

claim.

We review CINA proceedings de novo. In re K.N., 625 N.W.2d 731, 733

(Iowa 2001). “Although we give weight to the juvenile court’s factual findings, we

are not bound by them.” Id.

The mother argues the juvenile court wrongly placed the child in the

department’s custody rather than hers at the dispositional hearing; she does not

appeal the child’s adjudication as CINA. The child was adjudicated CINA under

Iowa Code section 232.96A(3)(b), which allows the court to adjudicate a child CINA

if “[t]he child has suffered or is imminently likely to suffer harmful effects as a result 5

of . . . [t]he failure of the child’s parent, guardian, custodian, or other member of

the household in which the child resides to exercise a reasonable degree of care

in supervising the child.” Iowa Code section 232.99(4) directs the court, following

a dispositional hearing, to “make the least restrictive disposition [4] appropriate

considering all the circumstances of the case,” which the mother argues was to

return the child to her custody.

With the child’s best interests as our polestar, we cannot agree with the

mother. See In re J.S., 846 N.W.2d 36, 40 (Iowa 2014) (“Our primary concern [in

CINA proceedings] is the child[’s] best interests.”). The mother had not assuaged

the drug concerns that initially brought the family to the department’s attention and

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Related

In the Interest of A.M.H.
516 N.W.2d 867 (Supreme Court of Iowa, 1994)
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 K.N.
625 N.W.2d 731 (Supreme Court of Iowa, 2001)

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