In the Interest of R.P., Minor Child

CourtCourt of Appeals of Iowa
DecidedJanuary 24, 2024
Docket23-1735
StatusPublished

This text of In the Interest of R.P., Minor Child (In the Interest of R.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.

Bluebook
In the Interest of R.P., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1735 Filed January 24, 2024

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

E.P., Father, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Pottawattamie County, Scott Strait,

District Associate Judge.

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

Eric A. Checketts of Checketts Law, PLC, Glenwood, for appellant father.

Brenna Bird, Attorney General, and William E. Sales III, Assistant Attorney

General, for appellee State.

Daniel McGinn of McGinn Law Firm, Council Bluffs, attorney and guardian

ad litem for minor child.

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

BOWER, Chief Judge.

A father appeals the termination of his parental rights to his child.1 Because

clear and convincing evidence supports a statutory ground for termination,

termination is in the best interests of the child, an application of a permissive

exception is not warranted, and the department of health and human services

(department) made reasonable efforts toward reunification, we affirm.

I. Background Facts and Proceedings

The child was born in November 2022, testing positive for marijuana. At the

time of the child’s birth, the father was in jail for violating a no-contact order

between the parents. The parents did not have a home and were “staying from

place to place.” The child was removed from the mother’s custody and adjudicated

in need of assistance. Earlier that year, the parents’ parental rights had been

terminated to another child, who was born in August 2021. This child was placed

with the same foster family that had adopted the parents’ older child.

The father participated in one supervised visit with the child in January

2023. That was the only in-person contact the father had with the child. Later that

month the father was arrested for violating the no-contact order again and

providing a false name to officers.

The father was released in March. He moved to Lincoln, Nebraska, and

then to Council Bluffs, but he would not disclose his address. He reported he was

“actively using methamphetamines and THC,” but he was “ready to make a change

1 The mother consented to termination of her parental rights. 3

in order to have a relationship with his child.” The father was ordered to participate

in drug screens, but he was a “no show” to both requested screens.

The father was arrested for forgery in April. He reported he was “actively

using methamphetamines on the day of his arrest.” The father was then

“kicked . . . out” of a rehabilitation center because he had “a mental breakdown.”

He pled guilty to forgery, and the court sentenced him to thirty days in jail followed

by supervised probation.

The State initiated termination-of-parental-rights proceedings in June. The

termination hearing took place in September. The father was living in a residential

treatment facility. He had engaged in video visits with the child. He testified he

had been sober for “about two months” and was “working on getting a job as we

speak, and also . . . at apartments . . . to be able to provide for [the child]” upon his

release from the facility. Although he believed the child could be returned to his

custody immediately, he asked for additional time to “show proof that [he is] clean,

sober, and having a stable living and a stable job.” The department and guardian

ad litem opined termination of the father’s parental rights would be in the best

interests of the child.

The court thereafter entered an order terminating the father’s parental rights

pursuant to Iowa Code section 232.116(1)(e), (h), and (l) (2023). The father

appeals.

II. Standard of Review

We review termination-of-parental-rights proceedings de novo. In re A.B.,

957 N.W.2d 280, 293 (Iowa 2021). Our paramount concern in termination

proceedings is the best interests of the child. In re L.T., 924 N.W.2d 521, 529 4

(Iowa 2019). We give weight to, but are not bound by, the juvenile court’s fact

findings. In re A.S., 906 N.W.2d 467, 472 (Iowa 2018).

III. Discussion

A. Grounds for Termination. The father’s rights were terminated on multiple

grounds; we may affirm if any one of the grounds is supported by the record. See

In re A.B., 815 N.W.2d 764, 774 (Iowa 2012) (“When the juvenile court terminates

parental rights on more than one statutory ground, we may affirm the juvenile

court’s order on any ground we find supported by the record.”). We focus on

paragraph (h). The father only challenges the fourth element—whether the child

could be returned to his custody.2 This element is satisfied when the State

establishes the child cannot be safely returned to the parent at the time of the

termination hearing. In re T.W., No. 20-0145, 2020 WL 1881115, at *2–3 (Iowa

Ct. App. Apr. 15, 2020).

The father claims “[t]he simple fact is the child could have been placed with

[him].” The father’s own testimony belies his claim. He testified he would be at

the facility until May 2024, but he could “get off three months early” if he paid his

“probation fee.” Children were not allowed to live at the facility. The father also

claims “[t]here was no evidence offered to suggest that there was any threat of

harm to [the child] if he were to have been placed with [the father], nor was there

reasonably compelling evidence to suggest he would not have been well cared

for.” We disagree. The father has not taken advantage of services offered to him

since August 2021, which includes the time services were offered to him for his

2 The father also raises this claim in a separate issue; we address it here. 5

older child to whom his parental rights had been terminated. In that case, the

juvenile court noted the father had “never visited or interacted with his daughter,”

had “not engaged in any of the offered services,” and there were “serious concerns

regarding [his] substance abuse history” and domestic abuse. Similarly, in this

case, the father has failed to meaningfully engage in services to address the

department’s same concerns, and those concerns remained present at the time of

the termination hearing. As the juvenile court found:

[The father] has not prioritized his relationship with his son. He has continued to commit criminal law violations which resulted in his incarceration and separation from his son. He has continued to use illicit substances and has failed to maintain sobriety. He testified at the termination hearing that he last used approximately 60 days before the hearing. He has failed to complete any substance abuse treatment or document any period of prolonged sobriety. He did not regularly visit [the child], nor has he developed a relationship or bond with his son. [The father] has failed to place himself in a position to safely and appropriately care for his son. The child cannot be safely returned to the care of his father now or in the foreseeable future.

We concur with the court’s assessment. Iowa Code section 232.116(1)(h) was

satisfied.

B. Best Interests.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

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 L.T., A.T., and D.T., Minor Children
924 N.W.2d 521 (Supreme Court of Iowa, 2019)
In the Interest of C.B.
611 N.W.2d 489 (Supreme Court of Iowa, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of R.P., Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-rp-minor-child-iowactapp-2024.