Background
The Iowa Department of Health and Human Services became involved in November 2024 after allegations that the mother struck the father with an extension cord in the child’s presence. Authorities had also investigated the parents in Illinois following the death of another child, and both parents were placed in Illinois’s child-abuse-and-neglect tracking system for “Death by Neglect.” The juvenile court removed A.M., who was born in 2024.
Domestic-violence concerns continued after removal, with repeated police calls involving the parents. The mother began but did not complete a domestic-abuse program, and neither parent consistently attended recommended individual therapy. Service providers also reported that the mother appeared disengaged during supervised visits and did not consistently use taught safety skills.
The Court’s Holding
The Iowa Court of Appeals affirmed termination of the mother’s parental rights. It held that the mother waived her sole appellate contention—that A.M. could safely be returned at the time of the termination hearing—because she offered no substantive analysis supporting it.
Addressing the merits nonetheless, the court concluded that clear and convincing evidence supported termination under Iowa Code section 232.116(1)(e). A.M. had been adjudicated in need of assistance and removed for more than a year, while the mother failed to maintain significant and meaningful contact through engagement with ordered services and visits. Termination also served A.M.’s best interests given the unresolved domestic violence and the child’s exposure to it. The mother did not establish a permissive exception to termination.
Key Takeaways
- An appellant waives an issue by asserting it without substantive argument or analysis.
- Failure to engage in ordered services and meaningful visitation can support termination under section 232.116(1)(e).
- Continuing domestic violence and a child’s exposure to it support a best-interests finding favoring termination.
Why It Matters
The decision underscores that parents appealing termination orders must develop their arguments, not merely state a disagreement with the juvenile court. It also illustrates how persistent domestic violence, incomplete services, and limited engagement during supervised contact can combine to support termination.