Background
D.S., the father of two children, filed a petition under Iowa Code chapter 600B seeking to establish custody and visitation. The district court dismissed the petition because the father’s parental rights to the children had been terminated in 2024.
Representing himself on appeal, the father challenged the dismissal and raised numerous claims in his opening and reply briefs. The Iowa Court of Appeals considered the case without oral argument.
The Court’s Holding
The Court of Appeals affirmed the dismissal. It held that, because the father’s parental rights had been terminated, he lacked standing to state a claim for custody and visitation under chapter 600B.
Reviewing the standing ruling for errors at law, the court found no error. It affirmed without further opinion under Iowa Court Rule 21.26(1)(d) and (e).
Key Takeaways
- A parent whose parental rights have been terminated lacks standing to pursue custody and visitation under Iowa Code chapter 600B.
- The court reviewed the dismissal for lack of standing for errors at law.
- The Court of Appeals affirmed the district court’s dismissal without further opinion.
Why It Matters
The decision confirms that termination of parental rights forecloses a later chapter 600B action seeking custody or visitation concerning the same children. The threshold standing defect permitted dismissal without consideration of the father’s other appellate claims.