Background
C.O., born in 2016, was one of the mother’s eleven children. The family had a lengthy history with Iowa’s Department of Health and Human Services. C.O. and his younger siblings were adjudicated children in need of assistance in May 2024 and removed from the parents’ custody that August.
The State sought termination of the parents’ rights to six children in August 2025. C.O.’s case was delayed because of service issues involving his biological father, while the parents’ rights to C.O.’s five younger siblings were terminated in February 2026 and that decision was later affirmed. After that termination, the mother and legal father did not meaningfully participate in services or drug testing and said they no longer wanted supervised visits, though they continued informal contact with C.O., who was living with maternal great-grandparents.
The Court’s Holding
The Iowa Court of Appeals affirmed the juvenile court’s May 2026 order terminating both the mother’s and legal father’s parental rights under Iowa Code section 232.116(1)(e). Reviewing de novo, the court concluded the State proved by clear and convincing evidence that the parents had not maintained significant and meaningful contact with C.O. and had made no reasonable efforts to resume his care despite having the opportunity.
The court also held termination served C.O.’s best interests. It found no permissive exception to termination applied and rejected guardianship as an alternative, noting that guardianship is not legally preferred over termination and that financial concerns weighed against it. C.O. had spent years in temporary arrangements, and family members were willing to adopt him.
Key Takeaways
- Failure to engage meaningfully in services, drug testing, and supervised visitation supported termination under section 232.116(1)(e).
- The court treated its prior analysis affirming termination as to C.O.’s younger siblings as equally applicable to C.O.
- A potential guardianship did not displace the need for a permanent adoptive home.
Why It Matters
The decision underscores that a parent’s continued lack of engagement after related termination proceedings can support a finding that the parent has not made reasonable efforts to resume care. It also reinforces Iowa’s preference for permanency through termination and adoption when guardianship would leave a child without the same level of stability.