N.H., on behalf of R.W. and A.W., Minor Children

CourtCourt of Appeals of Iowa
DecidedMay 26, 2021
Docket20-0872
StatusPublished

This text of N.H., on behalf of R.W. and A.W., Minor Children (N.H., on behalf of R.W. and A.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
N.H., on behalf of R.W. and A.W., Minor Children, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0872 Filed May 26, 2021

N.H., on behalf of R.W. and A.W., Minor Children, Petitioner-Appellee,

vs.

L.W., Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Jasper County, Thomas P. Murphy,

Judge.

L.W. appeals the district court’s grant of a sexual abuse protective order

under Iowa Code chapter 236A (2020). REVERSED.

Laura A. Eilers of Peglow, O’Hare & See, P.L.C., Marshalltown, for

appellant.

N.H., Newton, self-represented appellee.

Considered by Bower, C.J., and Vaitheswaran and Greer, JJ. 2

GREER, Judge.

This matter involves the grant of a sexual abuse protective order based on

an allegation that L.W. sexually abused his minor relative, R.W. In May 2020,

R.W.’s mother, N.H., petitioned for, and the district court granted, a final sexual

abuse protective order providing “[L.W.] is restrained from committing further acts

of sexual abuse or threats of sexual abuse. [L.W.] is restrained from any contact

with the Petitioner/Protected Party.”1 Shortly after filing the petition, N.H. filed two

child protective services child-abuse assessment summaries (CPS summaries).

One CPS summary was from 2016, which confirmed a sexual abuse allegation

against L.W. as founded. The other, a 2020 CPS summary, related to an Iowa

Department of Human Services (DHS) investigation of R.W.’s father for denial of

critical care by failing to provide proper supervision resulting from allegations the

father allowed R.W. to be around L.W. The 2020 investigation and CPS summary

concluded the allegation was not confirmed because the father had no knowledge

of the 2016 confirmed finding of abuse.

Citing several theories, L.W. appeals. He claims prejudice by the district

court’s consideration of the 2016 CPS summary because (1) it did not have

authority to access the report and (2) the report was not made part of the record

for the court’s consideration. L.W. next argues N.H. did not have authority to re-

disseminate either CPS summary that she filed with the district court. L.W. further

claims the finding of sexual abuse was not supported by a preponderance of the

1R.W. and a minor sibling, A.W., were listed as protected parties in the court’s final protective order. A.W. was listed on the petition as a child “whose welfare may be affected by this controversy.” 3

evidence, the district court erred in finding L.W. posed a “credible threat” to R.W.,

and the district court erred in including A.W. in the protective order. Finally, L.W.

claims the district court erred in not sua sponte continuing the hearing—which was

held virtually—considering the technical difficulties that occurred.

I. Facts and earlier proceedings.

Self-represented N.H. petitioned for relief from sexual abuse on behalf of

her minor child, R.W. (born in 2012) in May 2020, pursuant to Iowa Code section

236A.3 (2020). N.H. named L.W., the child’s paternal uncle, as the respondent.

The district court issued a temporary protective order pending a hearing on the

petition. From our review of the record, we glean that there was a 2016 allegation

L.W. sexually abused R.W. Each party here represented the DHS report was

founded but that L.W. received no notice of that nor was he given the opportunity

to dispute the finding. No criminal charges were ever filed against L.W., and there

were disputed allegations about a different perpetrator of abuse against R.W.

Turning now to March 2020, DHS began investigating a claim that R.W.’s

father was allowing L.W. to be around R.W. It was confirmed L.W. had been

temporarily residing in his grandparents’ home with R.W. After N.H. got DHS

involved, L.W. moved out of the grandparents’ home, but N.H. brought this present

action to keep L.W. from having any further contact with R.W.

L.W. thought the 2016 sexual abuse allegation was “dropped,” although he

never received any notice from DHS that the 2016 case had been closed. There

were no new allegations of sexual abuse against L.W. since the 2016 investigation. 4

A hearing on N.H.’s petition was scheduled for late May 2020, and it was

conducted by video conference through GoToMeeting2 due to the COVID-19

public health emergency. N.H. appeared telephonically and was not represented

by counsel. L.W. appeared by video with counsel. The district court asked L.W.

at the outset whether he consented to the audio and video virtual format of the

hearing, and he agreed. However, at multiple points throughout the hearing there

were audio disruptions that made it difficult for the parties to hear each other. At

no point did anyone ask the court to end the hearing or continue it due to the

technological issues.

L.W. moved to dismiss the petition shortly after the hearing began. His

counsel argued

The allegations of the sexual abuse were in 2016; and it was investigated by the [DHS]. It was my client’s understanding that it was being dismissed; it wasn’t. It wasn’t appealed but it was investigated by law enforcement. No charges were filed. Nothing happened since 2016 until this year when he moved in. [J.W.3] lived with his mother; and the two children [J.W.] has primary care of . . . and [L.W.] moved in for two weeks because he was involved in an accident and had a concussion issue. He’s not living there any longer. [DHS] became involved just because of the founded abuse; and when that was noted—known by [J.W.], [L.W.] left the residence immediately. And so we don’t think it’s timely. These allegations are 2016. We don’t think [L.W. is] an appropriate person for a 236 action, in that he’s not a resident of the party; it’s not like a—allegations of one of the parents here or another child or someone living in the home. And so that goes for our motion to dismiss. We don’t think it’s an appropriate 236 action. And then when we get to the merits of

2 GoToMeeting is a videoconferencing program. 3 J.W. is the children’s father. 5

the case, our position is that there’s no basis for a no-contact order based on the evidence that the court would hear.

(Emphasis added.)

Next, N.H. presented her evidence and testified. She started by agreeing

with L.W.’s counsel that “there is a case in 2016 of a founded sexual abuse in the

second degree by [L.W.].” No other details of the 2016 DHS investigation were

proffered. She voiced concern once L.W. moved into the paternal grandparents’

home where R.W. resided with his father. N.H. became upset upon learning L.W.

spent time alone with R.W. when he took him to get a haircut. In late February

2020, she confronted L.W.’s father with her concerns. N.H. said the father did not

want to believe the allegations and resisted her pleas to get L.W. out of the house

because L.W. was struggling financially.4 N.H. then contacted DHS, prompting the

denial-of-critical-care investigation that was ultimately unfounded.5 According to

N.H., it was not until DHS got involved that L.W. left the grandparents’ home and

ceased all contact with R.W.

After the mother’s evidence, L.W. moved for a directed verdict, presenting

similar arguments he made in his motion to dismiss.

I don’t think that there is [a] showing by the testimony heard today that there was any sexual abuse by [L.W.] . . . . . . . [T]here is no showing that [L.W.] is a family or household member; and that it’s stale based on the timing of the allegations.

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N.H., on behalf of R.W. and A.W., Minor Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nh-on-behalf-of-rw-and-aw-minor-children-iowactapp-2021.