In the Interest of P.K., Minor Child

CourtCourt of Appeals of Iowa
DecidedMay 11, 2022
Docket22-0384
StatusPublished

This text of In the Interest of P.K., Minor Child (In the Interest of P.K., 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 P.K., Minor Child, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0384 Filed May 11, 2022

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

J.K., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Worth County, Adam D. Sauer,

District Associate Judge.

The father appeals the order terminating his parental rights. AFFIRMED.

Cameron M. Sprecher of Sprecher Law Office, PLC, Mason City, for

appellant father.

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

Attorney General, for appellee State.

Gina Jorgensen, Hampton, attorney and guardian ad litem for minor child.

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

AHLERS, Judge.

P.K. is a three-year-old child. The State petitioned to terminate the parental

rights of the child’s father. The State did not seek to terminate the rights of the

child’s mother. Following a hearing, the juvenile court terminated the father’s

rights. He appeals.

I. Background

This family first came to the attention of the Iowa Department of Human

Services (DHS) in 2019 due to allegations that the father was caring for the child

while under the influence of methamphetamine. A child abuse assessment was

founded after the father admitted methamphetamine use and he was determined

to have abused the child’s mother. The juvenile court eventually ordered the

father’s removal from the family home due to failure to comply with DHS

requirements. The child was adjudicated in need of assistance. At the beginning

of DHS involvement, the child was placed with her paternal grandmother, but the

child was eventually returned to her mother’s custody.

During nearly two years of DHS involvement with the father, he has been

offered numerous services, including substance-abuse evaluations and treatment

services; family safety, risk, and permanency services; family-centered services;

mental-health services; family team meetings; a parent partner; family treatment

court involvement; and visitation with the child. The father’s engagement with

these services has been sporadic. Of primary concern is the father’s substance

abuse. He has had a few periods of sobriety, but he has largely provided positive 3

drug tests, has tampered with several drug tests, and has failed to engage

consistently in treatment.

The current termination-of-parental-rights proceeding is the second such

proceeding against the father regarding this child. Nearly one year prior to the

present proceeding, the State filed a petition seeking to terminate the rights of both

parents. After a hearing, the juvenile court denied the termination petition and

gave both parents an additional six months to work toward reunification. The

mother utilized those six months to improve to the point that the child was returned

to her care. The father did not utilize the extension to improve. The father is in

largely the same, if not a worse, position as he was at the time of the prior

termination hearing. In the few months before the termination hearing in the

current proceeding, he completely disengaged from services and failed to contact

service providers. He has struggled significantly with maintaining stability in his

life. His employment history has been spotty, with periods of unemployment and

bouncing from job to job. As of the termination hearing, the DHS was unable to

confirm any employment for him for several months, though he testified he would

begin a new job the day after the hearing. At the time of the hearing, the father

was facing eviction from his apartment due to unpaid rent.

Following a hearing, the juvenile court terminated the father’s parental

rights. The father appeals.

II. Standard of Review

Our standard of review is as follows:

In termination-of-parental-rights cases, we review the proceedings de novo. We are not bound by the juvenile court’s 4

findings of fact, but we do give them weight, especially in assessing the credibility of witnesses. There must be clear and convincing evidence of the grounds for termination of parental rights. Evidence is considered clear and convincing when there are no serious or substantial doubts as to the correctness [of] conclusions of law drawn from the evidence.[1]

III. Analysis

A. The Three-Step Analysis

Termination of parental rights under chapter 232 follows a three-step analysis. First, the court must determine if a ground for termination under section 232.116(1) has been established. If a ground for termination is established, the court must, secondly, apply the best-interest framework set out in section 232.116(2) to decide if the grounds for termination should result in a termination of parental rights. Third, if the statutory best-interest framework supports termination of parental rights, the court must consider if any statutory exceptions set out in section 232.116(3) should serve to preclude termination of parental rights.[2]

If a parent does not challenge one of the steps, we do not address that step.3

B. Issues Raised

The father makes three arguments on appeal: (1) the State failed to prove

statutory grounds for termination; (2) he should have been given an additional six

months to work toward reunification; and (3) he has a close bond with the child

that should prevent termination. We address each of these issues separately.

1. Statutory Grounds

The juvenile court terminated the father’s parental rights to the child

pursuant to Iowa Code section 232.116(1)(h) (2021). For termination under this

1 In re M.W., 876 N.W.2d 212, 219 (Iowa 2016) (alteration in original) (internal citations and quotation marks omitted). 2 In re D.W., 791 N.W.2d 703, 706-07 (Iowa 2010) (internal citations omitted). 3 In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). 5

subparagraph, the State must prove:

(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, 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.[4]

On appeal, the father only challenges the fourth element—that the child

could not be returned to his care at the time of the hearing.5

The primary impediment to the father gaining custody of the child is his

substance-abuse problem with methamphetamine. At the time of the termination

hearing, the father was still limited to fully supervised visits with the child due to his

methamphetamine problem.6 Throughout the lengthy duration of his case, the

father was offered numerous treatment opportunities. His engagement with

treatment has been sporadic. At the time of the termination hearing, he had not

been engaged in treatment for several months. Although the father had some

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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.W. and Z.W., Minor Children, R.W., Mother
876 N.W.2d 212 (Supreme Court of Iowa, 2016)
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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