In the Interest of A.G., R.G., and K.H., Minor Children, C.B., Father, T.G.-h., Mother, 17-1177

Background

DHS first involved Aug 2014 after newborn R.G. tested positive for THC; mother agreed to in-home services but soon missed treatment, refused supervision for drug tests, and home conditions were cluttered.
Children A.G. and R.G. removed Nov 2014; returned April 2016 after mother completed some treatment and stabilized, but concerns about marital discord and home conditions remained.
K.H. born 2015 and initially stayed with mother; all three children removed Aug 2016 after a physical altercation with maternal grandmother (resulting in a broken arm) and escalating unsanitary home conditions, maternal lapse of psychiatric medication, and concerns about drug use.
From Aug 2016 to termination hearing (June 2017) the mother regressed: filthy home with animal feces, kept animals and wood chips in bedrooms, missed drug tests, stopped mental-health meds, arrested for domestic violence, and visits were restricted for safety.
Juvenile court terminated mother’s parental rights under Iowa Code § 232.116(1)(f), (h), and (l); mother appealed arguing statutory grounds were not met, requesting six more months, and asserting termination was not in children’s best interests.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory grounds for termination under § 232.116(1)(f) and (h) were met (specifically that children could not be returned at time of hearing)	Mother: children could be returned because she planned to move to a new home and get a "fresh start."	State: mother had regressed (unsanitary home, missed tests, stopped meds, violence) and could not safely resume care now.	Affirmed: clear and convincing evidence children could not be returned at hearing.
Whether additional six months would allow reunification under § 232.104(2)(b)	Mother: additional time would permit progress and reunification.	State: mother made no recent progress; conditions persisted and likely would continue.	Denied: no reason to believe six months would remedy conditions.
Whether termination was in children's best interests	Mother: she shares a bond and can regain custody, keep siblings together.	State/guardian: children were placed together with foster family seeking adoption; they were bonded and making progress; need for permanency outweighs continued delay.	Affirmed: termination serves children's best interests; permanency favored.
Whether appellants other than mother (father; husband) could preserve parent-child relationship or raise arguments on mother's behalf	Father tried to support mother’s appeal; mother attempted to argue for husband	Appellate court: one parent cannot assert another parent’s defenses; mother lacks standing to argue on husband’s behalf.	Affirmed: father and mother cannot press arguments for other parents; father conceded inability to be custodial.

Key Cases Cited

In re C.B., 611 N.W.2d 489 (Iowa 2000) (standard for de novo review of termination proceedings)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (court may affirm termination on any supported ground; interpretation of "at the present time")
In re K.R., 737 N.W.2d 321 (Iowa Ct. App. 2007) (one parent lacks standing to assert another parent's defenses)
In re D.G., 704 N.W.2d 454 (Iowa Ct. App. 2005) (parents cannot assert facts or legal positions belonging to another parent)
In re J.E., 723 N.W.2d 793 (Iowa 2006) (children's best interests prioritize safety and need for a permanent home)