In the Interest of A.B., Minor Child, 956 N.W.2d 162

A.B., a child under three, was removed from parental custody and the State sought termination of both parents’ rights under Iowa Code § 232.116(1)(h).
The parents have long histories of substance abuse, including methamphetamine; both refused drug screens in Jan 2021 and later tested positive for methamphetamine in Feb 2021.
A.B. initially tested positive for methamphetamine at case outset and has ongoing, serious health and developmental needs requiring regular medical appointments and therapies.
While in parents’ care, required therapies were not consistently completed and parents missed many medical appointments after placement in foster care.
The juvenile court admitted the Feb 2021 drug-test results; both parents appealed termination and challenged the admission (foundation/hearsay) and sufficiency of evidence that A.B. could not be returned safely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 232.116(1)(h) element — child cannot be returned at present — was proven	Parents: insufficient evidence that child could not be safely returned	State: ongoing meth use (including refused tests presumed positive and Feb 2021 positives) + missed medical care for A.B. make return unsafe	Affirmed. Clear and convincing evidence child could not be returned
Admissibility/authentication of Feb 2021 drug-test results	Mother: tests lack foundation/inaccurate; Father: hearsay and lack of foundation	State: technicians and lab supervisor testified to collection, testing, and identification; business-records exception applied	Admission upheld as adequately authenticated; even if excluded, record still supports termination
Mother's claim of lack of reasonable efforts toward reunification	Mother: State failed to provide reasonable efforts (relies on materials from 2018)	State/Court: those materials are not in the appellate record so claim is unpreserved/unsupported	Court declined to consider due to lack of record; argument not addressed on merits

In re J.S., 846 N.W.2d 36 (Iowa 2014) (parental methamphetamine use creates dangerous environment for children)
State v. Musser, 721 N.W.2d 734 (Iowa 2006) (authentication and foundation for laboratory/testing evidence)
State v. Dessinger, 958 N.W.2d 590 (Iowa 2021) (standard of review for hearsay rulings)
Bremicker v. MCI Telecomm. Corp., 420 N.W.2d 427 (Iowa 1988) (trial court discretionary rulings presumed correct)
Cass Cnty. v. Audubon Cnty., 266 N.W. 293 (Iowa 1936) (presumption that court action is regular and lawful)