In the Interest of W.S., Minor Child

CourtCourt of Appeals of Iowa
DecidedJune 16, 2021
Docket21-0264
StatusPublished

This text of In the Interest of W.S., Minor Child (In the Interest of W.S., 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 W.S., Minor Child, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-0264 Filed June 16, 2021

IN THE INTEREST OF W.S., Minor Child,

D.S., Father, Appellant,

R.P., Mother, Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Dubuque County, Thomas J. Straka,

Associate Juvenile Judge.

A mother and father separately appeal the termination of their respective

parental rights. AFFIRMED ON BOTH APPEALS.

Gina L. Kramer of Reynolds & Kenline, L.L.P., Dubuque, for appellant

father.

Benjamin Hamel of Iowa Legal Aid, Dubuque, for appellant mother.

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

Attorney General, for appellee State.

Bridget Goldbeck, Dubuque, attorney and guardian ad litem for minor child.

Considered by Tabor, P.J., Ahlers, J., and Gamble, S.J.*

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

(2021). 2

GAMBLE, Senior Judge.

A mother and father separately appeal the termination of their respective

parental rights to their child, W.S. The parents argue termination is not in W.S.’s

best interest and request additional time to work toward reunification.

I. Scope and Standard of Review

We review termination proceedings de novo. In re P.L., 778 N.W.2d 33, 40

(Iowa 2010). “We give weight to the factual determinations of the juvenile court

but we are not bound by them. Grounds for termination must be proven by clear

and convincing evidence. Our primary concern is the best interests of the child.”

In re J.E., 723 N.W.2d 793, 798 (Iowa 2006) (citations omitted).

We typically use a three-step process to review the termination of a parent’s

rights. In re A.S., 906 N.W.2d 467, 472 (Iowa 2018). First, we determine whether

a ground for termination under section 232.116(1) has been established. See id.

at 472–73. If a ground for termination has been established, then we consider

“whether the best-interest framework as laid out in section 232.116(2) supports the

termination of parental rights.” Id. at 473 (citation omitted). Then we consider

“whether any exceptions in section 232.116(3) apply to preclude termination of

parental rights.” Id. (quoting In re M.W., 876 N.W.2d 212, 220 (Iowa 2016)).

“However, if a parent does not challenge a step in our analysis, we need not

address it.” In re J.P., No. 19-1633, 2020 WL 110425, at *1 (Iowa Ct. App. Jan. 9,

2020). Following our three-step process, we consider any additional claims

brought by the parent. See In re T.P., No. 19-0162, 2019 WL 3317346, at *2 (Iowa

Ct. App. July 24, 2019). 3

II. Discussion

A. Statutory Grounds

The juvenile court terminated the parents’ parental rights, pursuant to Iowa

Code section 232.116(1)(h) and (l) (2021), after the parents stipulated to the

statutory grounds. Neither parent attempts to challenge the statutory grounds

authorizing termination on appeal. So we move to the next step in our analysis.

See In re Z.S., No. 21-0004, 2021 WL 1906363, at *1 (Iowa Ct. App. May 12,

2021).

B. Best Interest

The parents challenge the juvenile court’s determination that termination of

their respective parental rights is in W.S.’s best interest.1 In considering the best

interest of W.S., we “give primary consideration to the child’s safety, to the best

placement for furthering the long-term nurturing and growth of the child, and to the

physical, mental, and emotional condition and needs of the child.” See P.L., 778

N.W.2d at 40 (quoting Iowa Code § 232.116(2)). “It is well-settled law that we

cannot deprive a child of permanency after the State has proved a ground for

termination under section 232.116(1) by hoping someday a parent will learn to be

a parent and be able to provide a stable home for the child.” Id. at 41.

1 To the extent the father attempts to challenge the best-interest determination with respect to the mother’s parental rights, he does not have standing. See In re D.G., 704 N.W.2d 454, 460 (Iowa Ct. App. 2005) (requiring parents advance their own claims on appeal and separate from the other parent); see also In re J.P., No. 19- 1633, 2020 WL 110425, at *2 n.4 (Iowa Ct. App. Jan. 9, 2020). The mother’s own best-interest argument is couched within her argument for additional time to work toward reunification. 4

We agree with the juvenile court that W.S.’s best interest requires

termination. Both parents point to their bond with W.S. as evidence that

termination is not in W.S.’s best interest. But safety is a “defining element[]” of our

best-interest analysis. In re J.E., 723 N.W.2d 793, 802 (Iowa 2006) (Cady, J.,

specially concurring); see Iowa Code § 232.116(2) (noting “the court shall give

primary consideration to the child’s safety”). Both parents have a history of

methamphetamine use. “A parent’s methamphetamine use, in itself, creates a

dangerous environment for children.” J.P., 2020 WL 110425, at *2. That truth was

borne out when W.S. tested positive for methamphetamine at the beginning of this

case. And we anticipate the parents’ drug use will continue. In fact, at the

termination hearing, the father admitted to using methamphetamine a little over a

week prior. He is not in any substance-abuse treatment program to mitigate

concerns of continued use moving forward. And the mother’s two most recent

sweat patch tests were positive for methamphetamine.2 The parents’ continued

methamphetamine use creates a safety risk to W.S.

So termination of their parental rights is in W.S.’s best interest.3 We move

to our next step.

2 We note the mother denies recent methamphetamine use and claims her sweat patch tests were positive due to methamphetamine use by others around her. Even if this is true, it demonstrates the mother continues to interact with methamphetamine users, which increases the likelihood of her relapse. Moreover, the mother conceded had W.S. been in her care, W.S. likely also would have tested positive for methamphetamine. 3 The mother also argues against termination because it would “prevent [the

mother] from having one final opportunity to establish that the child could be safely placed with her.” To the extent she attempts to present this argument as a best- interest argument, she misses the mark. When making a best-interest assessment, we do not look to what would be most beneficial to the parent. Instead, we look at whether termination would be the most beneficial option for the 5

C. Exceptions to Termination

For our third step, we consider whether we should apply any of the Iowa

Code section 232.116(3) exceptions to preclude termination. Neither parent asks

us to apply an exception to termination. So we do not consider this step and

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Related

In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
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 D.G.
704 N.W.2d 454 (Court of Appeals of Iowa, 2005)

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