In the Interest of W.G.-C., Minor Child

CourtCourt of Appeals of Iowa
DecidedAugust 7, 2024
Docket24-0595
StatusPublished

This text of In the Interest of W.G.-C., Minor Child (In the Interest of W.G.-C., 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 W.G.-C., Minor Child, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-0595 Filed August 7, 2024

IN THE INTEREST OF W.G.-C., Minor Child,

S.Z., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Marshall County, Paul G. Crawford,

Judge.

The mother appeals the termination of her parental rights. AFFIRMED.

Chad Frese and Joel C. Waters of Kaplan & Frese, LLP, Marshalltown, for

appellant mother.

Brenna Bird, Attorney General, and Tamara Knight, Assistant Attorney

General, for appellee State.

Mary Cowdrey of Public Defender’s Office, Marshalltown, attorney and

guardian ad litem for minor child.

Considered by Badding, P.J., Buller, J., and Potterfield, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

POTTERFIELD, Senior Judge.

The juvenile court terminated the mother’s parental rights to five-year-old

W.G.-C. pursuant to Iowa Code section 232.116(1)(f) (2023). The mother appeals,

arguing the statutory ground for termination was not met and challenging whether

termination is in the child’s best interests since W.G.-C. remains in the custody of

his father.

Our review is de novo. In re L.B., 970 N.W.2d 311, 313 (Iowa 2022). This

means that while we respect the juvenile court’s factual findings, especially on

credibility issues, “we examine the whole record, find our own facts, and adjudicate

rights anew on issues properly before us.” Sun Valley Iowa Lake Ass’n v.

Anderson, 551 N.W.2d 621, 629 (Iowa 1996).

Statutory Grounds. The juvenile court terminated the mother’s parental

rights under section 232.116(1)(f), which allows for termination when:

(1) The child is four years of age or older. (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 twelve of the last eighteen months, or for the last twelve consecutive months and any trial period at home has been less than thirty days. (4) There is 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.

The mother challenges both the third and fourth element.

She argues the third element was not met because W.G.-C. was not

removed from the custody of both parents—the child was in the father’s custody

at the time of the termination trial. See Iowa Code § 232.116(1)(f)(3). But the

statute “allows the termination of parental rights of the noncustodial parent even 3

though legal custody of the child is placed with the other parent.” In re N.M., 491

N.W.2d 153, 156 (Iowa 1992); see also Iowa Ct. R. 4.1(17) (“Unless otherwise

specifically provided by law the singular includes the plural, and the plural includes

the singular.”). And here, it is undisputed that the district court entered a formal

order removing W.G.-C. from the mother’s custody in November 2022, which was

more than twelve months before the December 2023 termination hearing. See In

re M.W., 876 N.W.2d 212, 223 (Iowa 2016) (considering how long children had

been removed from parental custody at the time of the termination trial). So the

third element was met.

Next, the mother argues the fourth element was not met because W.G.-C.

could have been returned to her custody at the time of the termination trial. See

id. § 232.116(1)(f)(4). The mother points to her unresolved criminal charge for

child endangerment—arguing we cannot conclude W.G.-C. is unsafe in her care

“until [her] case and appeals have been exhausted”—and claims that drug use was

never confirmed at the family home. The mother’s interpretation of

section 232.116(1)(f)(4) is too narrow. Here, the Iowa Department of Health and

Human Services became involved with the family after police found

methamphetamine in the family home in November 2022. While W.G.-C. did not

test positive for methamphetamine at the time of removal, the mother did. The

mother also tested positive for methamphetamine in March, July, and October

2023. In fact, every time the mother drug tested for the department, the result was

positive for methamphetamine. And there is no reason to believe that the twenty-

three drug tests the mother missed would have been clean. See In re A.D., No. 20-

1182, 2020 WL 7022391, at *3 (Iowa Ct. App. Nov. 30, 2020) (collecting cases 4

where the court has presumed missed tests would have been positive for drugs).

The mother was generally not forthcoming regarding her substance use, and she

had not re-engaged in treatment following her positive tests. Overall, the mother

seemed unable or unwilling to internalize the impact her drug use had on her ability

to safely parent W.G.-C. But as our case law provides, “[a] parent’s

methamphetamine use, in itself, creates a dangerous environment for children.” In

re J.P., No. 19-1633, 2020 WL 110425, at *2 (Iowa Ct. App. Jan. 9, 2020); accord

In re J.S., 846 N.W.2d 36, 37 (Iowa 2014) (“[A] parent’s methamphetamine

addiction by itself can result in ‘harmful effects’ to the child, thereby justifying state

intervention to protect the child.”). The State proved W.G.-C. could not be returned

to the mother’s custody at the time of the termination trial.1

Best Interests and Permissive Factor. Next, the mother argues

termination of her parental rights is not in the child’s best interests because

W.G.-C. remained in his father’s custody.2 See Iowa Code § 232.116(2), (3)(a).

1 In another section of her brief, the mother mentions “reasonable efforts” in passing and argues they were not made. See In re C.B., 611 N.W.2d 489, 493 (Iowa 2000) (recognizing that “[t]he State must show reasonable efforts as a part of its ultimate proof the child cannot be safely returned to the care of a parent”). But the mother has neither fully developed an argument nor pointed us to where in the record she both raised the issue to the juvenile court and received a ruling. We do not consider this issue. See In re W.J., No. 21-1991, 2022 WL 610559, at *1 (Iowa Ct. App. Mar. 2, 2022) (finding a parent waived an issue by making only a “conclusory statement unaccompanied by factual arguments, legal arguments, legal citations, or references to the record”); In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005) (“The [d]epartment has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing. We conclude [the parent] has not preserved these claims for our review on appeal.” (internal citation omitted)). 2 We note that in the TPR order, the juvenile court stated, “No relative has legal

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

Related

Sun Valley Iowa Lake Ass'n v. Anderson
551 N.W.2d 621 (Supreme Court of Iowa, 1996)
In the Interest of N.M.
491 N.W.2d 153 (Supreme Court of Iowa, 1992)
In the Interest of C.K.
558 N.W.2d 170 (Supreme Court of Iowa, 1997)
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 C.B.
611 N.W.2d 489 (Supreme Court of Iowa, 2000)
In the Interest of A.A.G.
708 N.W.2d 85 (Court of Appeals of Iowa, 2005)
In the Interest of D.S.
806 N.W.2d 458 (Court of Appeals of Iowa, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of W.G.-C., Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-wg-c-minor-child-iowactapp-2024.