In the Interest of A.B. — Iowa court affirms termination of imprisoned father’s parental rights

Case
In the Interest of A.B., Minor Child
Court
Iowa Court of Appeals
Judge
Greer, P.J. (Kim Reynolds, 2019); Badding, J. (Kim Reynolds, 2021); Sandy, J. (Kim Reynolds, 2024)
Date Decided
October 7, 2026
Docket No.
26-1328
Topics
Parental rights; Child welfare; Termination; Incarceration
Source
Read the full opinion

Background

A father appealed the termination of his parental rights to A.B., a seven-year-old son he had never met. The father testified remotely from an Arizona prison that he wanted to form a relationship with the child and would have come to Iowa if he had not been incarcerated. But he had known about the child for more than seven years and had been imprisoned for less than two.

The father said he cut ties in 2019 after earlier tests purportedly excluded him as the biological father. He said he learned in September 2025 that he was A.B.’s father, but the Department of Health and Human Services case manager testified that he did not respond to outreach after then and did not seek services until March 2026. The juvenile court terminated his rights under Iowa Code section 232.116(1)(b), (e), and (f).

The Court’s Holding

The Iowa Court of Appeals affirmed after de novo review. Clear and convincing evidence supported the statutory grounds for termination, and termination served A.B.’s best interests. The child was thriving in a long-term placement that the mother described as happy and safe.

The court also found no permissive exception to termination applied. Although biological parents are entitled to a fair opportunity to contest termination, the court concluded that the father could not use his newly asserted interest in parenting to enter the life of a seven-year-old child with whom he had no relationship and whom he could not take custody of at the termination hearing.

Key Takeaways

  • A parent’s biological connection alone does not prevent termination when the parent has never participated in the child’s life.
  • Clear and convincing evidence supported termination under Iowa Code section 232.116(1)(b), (e), and (f).
  • The child’s stability and success in a long-term placement supported the best-interests finding.

Why It Matters

The decision underscores that a parent’s belated effort to establish a relationship does not outweigh a child’s need for permanence, particularly where the parent has long known of the child, has not engaged with services, and cannot assume custody at the hearing.

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