In the Interest of A.M., M.H.-m., and G.M., Minor Children, J.M., Father, D.H., Mother, 16-1752

Three children (A.M., b.2006; M.H.-M., b.2012; G.M., b.2013) were removed from parents’ custody in March 2015 after concerns about mother’s long-term substance abuse and serious mental-health issues and a history of domestic violence and unstable housing by the father.
Children were adjudicated CINA in May 2015 and placed with paternal grandmother (after a brief placement with maternal grandmother); paternal grandmother lives over two hours from parents and sought permanent custody.
Mother had multiple prior founded child-abuse assessments, suicide attempt and psychiatric hospitalization, ongoing mental-health diagnoses, and inconsistent participation in visits early in the case; father largely failed to cooperate early, later completed some domestic-violence and substance-abuse services, but had unstable housing and limited parenting history.
DHS arranged supervised visits, provided gas cards, and offered additional visits; parents did not schedule or fully use offered services and did not request a closer placement.
Juvenile court terminated both parents’ rights under Iowa Code §232.116(1)(f) (for A.M. and M.H.-M.) and (h) (for G.M.) after hearings in 2016; parents appealed, arguing lack of reasonable reunification efforts and father requested a six-month extension.
On de novo review, the appellate court affirmed termination, finding DHS made reasonable efforts and the father failed to show additional six months would eliminate the need for removal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether State proved statutory grounds for termination by clear and convincing evidence (reasonable efforts / inability to return children)	State: DHS made reasonable efforts (services, supervised visits, gas cards); children improved in placement; statutory elements satisfied.	Parents: DHS failed to make reasonable efforts — father alleges lack of transportation assistance; mother alleges refusal to place children closer to her.	Affirmed: DHS made reasonable efforts; children could not be returned to parents’ custody at hearing.
Whether father was entitled to a six-month extension under §232.104(2)(b)	Father: additional time would allow him to complete services and stabilize to reunify.	State: father showed poor participation, unstable housing, and limited parenting history; extension would not likely resolve need for removal.	Denied: court found father did not show removal need would end within six months.

In re M.W., 876 N.W.2d 212 (Iowa 2016) (standard of de novo review in TPR appeals)
In re A.M., 843 N.W.2d 100 (Iowa 2014) (weight given to juvenile court credibility findings)
In re J.E., 723 N.W.2d 793 (Iowa 2006) (best-interest primary consideration in termination)
Hyler v. Garner, 548 N.W.2d 864 (Iowa 1996) (appellate court will not construct undeveloped arguments)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (reasonable-efforts requirement affects State’s burden but is not absolute)
In re M.B., 553 N.W.2d 343 (Iowa Ct. App. 1996) (visitation controlled by child’s best interests)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (emphasis on child permanency and urgency)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (parental improvement cannot indefinitely delay permanency)
In re C.S., 776 N.W.2d 297 (Iowa Ct. App. 2009) (children’s rights to permanency can outweigh parental interests)