In the Interest of B.B., Minor Child, D.B., Father, 16-2002

B.B., an infant, was removed from parental custody in Feb 2016 and adjudicated a child in need of assistance under Iowa Code § 232.2(6)(c)(2) in June 2016.
After disposition, the juvenile court ordered temporary legal custody remain with the Department of Human Services for family foster care.
Father (Doug) appealed both the adjudication and the dispositional order, arguing insufficient evidence supported adjudication and that the child should have been placed with him as the least restrictive alternative.
No transcript or record of the adjudication hearing was provided on appeal; father did not reconstruct the record.
At the time of disposition father had made progress in therapy but had not resolved issues including aggressive/controlling behavior, boundary problems, unhealthy relationships, and a history of domestic violence; there were allegations during the case he struck the mother and had a violent history with an ex-wife who had previously stabbed him.
The appellate court affirmed: it refused to review the adjudication due to lack of record, and it affirmed the dispositional placement in foster care as the least restrictive appropriate alternative given unresolved safety risks.

Issue	Father's Argument	State's Argument	Held
Whether the adjudication was supported by clear and convincing evidence	The State failed to prove the statutory ground by clear and convincing evidence	The adjudication was properly supported by the record below	Affirmed — appellate review of adjudication precluded because appellant failed to provide the hearing transcript/record necessary to challenge evidentiary findings
Whether the juvenile court should have placed B.B. with father (least restrictive disposition)	Child should be placed with father as the least restrictive alternative	Continued placement in foster care was necessary until father remedied safety risks	Affirmed — foster care placement was the least restrictive appropriate disposition given unresolved domestic violence and related risks

In re D.D., 653 N.W.2d 359 (Iowa 2002) (standard of de novo review and clear-and-convincing evidence in CINA proceedings)
In re L.G., 532 N.W.2d 478 (Iowa Ct. App. 1995) (appellate de novo review of juvenile matters)
State v. Iowa Dist. Ct., 828 N.W.2d 607 (Iowa 2013) (describing effects of suspended judgment on custody)
In re F.W.S., 698 N.W.2d 134 (Iowa 2005) (appellate rule requiring record or reconstruction; consequences for failure)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (limits on appellate review without full record)
State v. Ludwig, 305 N.W.2d 511 (Iowa 1981) (appellant’s duty to provide record disclosing alleged error)
In re T.V., 563 N.W.2d 612 (Iowa 1997) (consequences when appellant fails to secure record under rule)