Background
In November 2025, C.H. brought her nine-year-old daughter, L.M., to an emergency department because of the child’s behavior. After C.H. left the room, L.M. told hospital personnel that her mother had hit her about six times before the visit. Hospital staff observed bruising on L.M.’s thighs, including a handprint-shaped bruise. L.M. said she did not feel safe with her mother because she was beaten “all the time.”
The emergency provider took protective custody, and L.M. was released to her father, who shared the child’s care. A forensic interview and physical examination were consistent with L.M.’s account. Her younger half-brother also reported fearing the mother and said she spanked both children frequently. The district court adjudicated L.M. a child in need of assistance under several provisions of Iowa Code section 232.96A and later continued her placement outside the mother’s custody. The mother appealed both orders.
The Court’s Holding
The Iowa Court of Appeals affirmed. It held that the mother waived her challenge because her appellate argument cited no legal authority and offered no additional justification refuting the district court’s determination, contrary to Iowa’s appellate briefing rules.
Even if the claim were properly presented, the court concluded that clear and convincing evidence supported the adjudication under Iowa Code section 232.96A(2). On de novo review, it agreed that L.M. suffered a nonaccidental physical injury resulting from the mother’s acts. The court also treated any challenge to the disposition order as waived because the mother mentioned that order but made no specific argument about it.
Key Takeaways
- An appellate argument unsupported by legal authority may be deemed waived.
- The record supported a finding that the child suffered nonaccidental physical injury caused by her mother.
- A party must specifically challenge a disposition order; merely mentioning it in the appeal is insufficient.
Why It Matters
The decision underscores that CINA appeals require developed, authority-supported arguments. It also confirms that a child’s statements, observed injuries, and corroborating forensic evidence can provide clear and convincing support for a physical-abuse-based CINA adjudication.