In the Interest of Z.K. and I.W., Minor Children

CourtCourt of Appeals of Iowa
DecidedDecember 3, 2025
Docket25-1256
StatusPublished

This text of In the Interest of Z.K. and I.W., Minor Children (In the Interest of Z.K. and I.W., Minor Children) 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 Z.K. and I.W., Minor Children, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 25-1256 Filed December 3, 2025

IN THE INTEREST OF Z.K. and I.W., Minor Children,

L.S.-R., Mother, Appellant. _______________________________________________________________

Appeal from the Iowa District Court for Webster County, Joseph McCarville,

Judge.

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

Brandy Lundy, Moorland, for appellant mother.

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

General, for appellee.

Ricki Osborn Stubbs of Osborn Stubbs Law Office P.C., Fort Dodge,

attorney and guardian ad litem for minor children.

Considered without oral argument by Badding, P.J., Sandy, J., and Bower,

S.J.*

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

(2025) . 2

BOWER, Senior Judge.

Following a mother’s lengthy history of substance use and failed drug tests,

the district court terminated her parental rights to two of her children, 1 born in 2019

and 2023.2 On appeal, the mother challenges the statutory grounds authorizing

termination, claims the Iowa Department of Health and Human Services failed to

make reasonable efforts toward reunification, argues a permissive exception

should be applied, and maintains her right to counsel was violated due to the

“current statutory court-appointed hourly rate.” We affirm.

I. Standard of Review and Applicable Law

We review termination orders de novo. In re J.V., 13 N.W.3d 595, 603 (Iowa

2024). We are not bound by the district court’s factual findings, but we give them

weight, especially in assessing witness credibility. Id. Our review follows a three-

step process to determine if a statutory ground for termination has been satisfied,

whether termination is in the children’s best interests, and whether any permissive

exception should be applied to preclude termination. In re A.B., 957 N.W.2d 280,

294 (Iowa 2021). We do not address steps not challenged by the parent. In re

P.L., 778 N.W.2d 33, 40 (Iowa 2010). After addressing any challenged steps, we

then consider any additional claims raised. In re L.A., 20 N.W.3d 529, 532 (Iowa

Ct. App. 2025).

1 The mother’s two older children are in the sole legal custody of their father. As the mother explained, the court ordered legal custody of the children with their father during the parents’ divorce proceeding because she “was on drugs at the time” and she “had no stable home.” In addition, a no-contact order was issued against the mother naming the children’s father as the protected party. 2 At the time the termination order was entered relating to the mother, the parental

rights of I.W.’s father and Z.K.’s father were not terminated. 3

II. Grounds for Termination

The court found the statutory grounds for termination satisfied under Iowa

Code section 232.116(1)(f) (2025) as to Z.K. and section 232.116(1)(h) as to I.W.

These two grounds require the child to be previously adjudicated in need of

assistance and for the court to find the child cannot be returned to the parent’s

custody at the time of the termination hearing. Iowa Code § 232.116(1)(f), (h).

They differ only with respect to the age of the child at issue and the length of time

the child must be removed from the parent’s custody. Compare id. § 232.116(1)(f),

with id. § 232.116(1)(h).

Under these grounds, the mother only challenges whether the children

could be safely returned to “the custody of the child’s parents” at the time of the

termination hearing. See id. § 232.116(1)(f)(4), (h)(4); In re A.M., 843 N.W.2d 100,

112 (Iowa 2014) (noting “at the present time” means at the time of the termination

hearing). According to the mother, because I.W. “has been returned” to her father

and Z.K. “will likely return” to his father, the State is “unable to meet [its] burden”

under section 232.116(1)(f)(4) and (h)(4). We reject this contention. “Parents” as

used in the statute includes “parent,” see In re R.M.-V., 13 N.W.3d 620, 625 (Iowa

Ct. App. 2024), and in this regard, implicates the court’s findings relating to the

mother, which she does not otherwise contest.

To further support her claim, however, the mother contends the department

failed to make reasonable efforts toward reunification. “While not a strict

substantive requirement for termination, the State must show reasonable efforts

toward reunification as part of its ultimate proof that the children cannot be safely

returned to the custody of a parent.” In re C.M., No. 25-0435, 2025 WL 1706340, 4

at *2 (Iowa Ct. App. June 18, 2025) (cleaned up). The mother raises the following

complaints.3

First, she claims the department failed to give her a hair stat test despite a

court order, thwarting her an opportunity to prove her sobriety. To be clear, the

mother maintained her sobriety date was August 4, 2024. She requested a hair

stat test after she repeatedly tested positive on sweat patch and urine tests after

that date. The court acknowledged the department had not obliged the mother’s

request for a hair stat test “due to how their system works and the mother’s positive

sweat patch.” Nonetheless, in March 2025, the court entered an order stating the

department “is authorized to [do] a hair stat test on the . . . mother.”

At the termination hearing, the caseworker acknowledged the hair stat test

had not yet been completed, explaining, “I am not able to enter the hair stat test

into the system when there is a positive test before that. There has to be a period

of time with negative testing, without a positive test, before I can enter a hair stat

test,” even when there is a court order. The caseworker further testified, since the

permanency hearing in April, the mother had completed two sweat patch tests,

both of which were positive. Yet the mother was “adamant that all of these times

with the positive drug tests, they were just positive but [she] never relapsed.” She

believed a hair stat test would have given her an opportunity to demonstrate

sobriety. Under these circumstances, although it is concerning the department did

3 In addition to the claims set forth below, the mother also argues the department’s

“contract” with family support services (FSS) providers “is a prima facie violation of the requirement to use reasonable efforts.” But this issue was neither raised before nor decided by the district court, so it is not preserved for review. Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“[I]ssues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”). 5

not complete a hair stat test, the mother had opportunities to test through both

urine and sweat patches. See id. at *3. However, “the mother could not

demonstrate any meaningful period of sobriety because her sweat-patch results

consistently came back positive for methamphetamine.” Id.

Next, the mother claims the department failed to inform her of the children’s

“medical procedures and obtain[] informed consent.” Specifically, Z.K. was

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

Related

Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
In Re P.L.
778 N.W.2d 33 (Supreme Court of Iowa, 2010)
In the Interest of A.M., Minor Child, A.M., Father
843 N.W.2d 100 (Supreme Court of Iowa, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
In the Interest of Z.K. and I.W., Minor Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-zk-and-iw-minor-children-iowactapp-2025.