In the Interest of A.C., Minor Child, B.C., Father, 16-1959

Infant A.C. (born Aug. 2015) suffered multiple rib fractures and other injuries by Oct. 2015; medical opinion was the injuries were inflicted by a caregiver and not explained by the parents.
Juvenile court adjudicated A.C. a CINA (Jan. 2016) and placed her in foster care; both parents denied responsibility and gave inconsistent explanations.
DHS provided supervised visitation (reduced over time for missed sessions); providers observed incidents of the father becoming angry and squeezing the child’s midsection during visits.
Father had longstanding mental‑health issues (diagnosed PTSD and provisional schizoaffective disorder; possible psychosis), resisted releases and missed therapy, and had not completed anger management by the termination hearing.
State petitioned to terminate parental rights; juvenile court terminated both parents under Iowa Code § 232.116(1)(d) and (i) and found termination served the child’s best interests; father appealed.

Issue	Father’s Argument	State’s Argument	Held
Whether DHS failed to make reasonable efforts to reunify by restricting in‑home visits and creating barriers	DHS created artificial/unnecessary barriers (no home visits), and transportation issues impeded attendance	DHS reasonably limited in‑home visits for child safety given father’s behavior, provided transportation assistance	DHS made reasonable efforts; restriction justified by child’s safety concerns
Whether statutory grounds for termination (Iowa Code § 232.116(1)(d) and (i)) were proven by clear and convincing evidence	Father argued services were not reasonable for months so circumstances did not continue to exist	State showed parents did not accept responsibility, father failed to remedy mental‑health/anger issues despite services	Clear and convincing evidence supported termination under subsection (d); affirmed (court may rest on any adequate ground)
Whether termination was contrary to A.C.’s best interests and whether a six‑month continuance was warranted	Father requested six more months, argued bond and need to resume parenting	State argued child’s safety and need for permanency outweighed delay; foster placement provided stability	Termination was in child’s best interests; six‑month extension denied

In re C.B., 611 N.W.2d 489 (Iowa 2000) (DHS reasonable‑efforts duty affects burden of proof but is not a strict substantive prerequisite to termination)
In re M.B., 553 N.W.2d 343 (Iowa Ct. App. 1996) (visitation scope is governed by child’s best interests)
In re A.A.G., 708 N.W.2d 85 (Iowa Ct. App. 2005) (parent must request additional services if current services are inadequate)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (appellate court may affirm termination on any statutory ground proved by clear and convincing evidence)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (best‑interests analysis must follow statutory framework)
In re M.W., 876 N.W.2d 212 (Iowa 2016) (termination proceedings reviewed de novo; factual findings given weight for credibility)
In re J.B.L., 844 N.W.2d 703 (Iowa Ct. App. 2014) (denial of six‑month continuance proper when parent cannot provide safe home and foster family offers stability)