In the Interest of B.T., Minor Child, N.T., Mother, 17-0773

B.T., born 2015 with a congenital heart defect and one kidney, was removed from parental custody in March 2015 after DHS involvement arising from parents’ homelessness, medical needs, and domestic violence.
The child required specialized feeding and ongoing medical care; parents and child had hygiene-related health issues at birth (lice/scabies treated).
The child was adjudicated CINA (child in need of assistance) in March 2015 and remained out of the mother’s care continuously through the termination hearing in April/May 2017; no trial home placements occurred.
The mother completed some training but admitted she was not current on the child’s medical/feeding needs and had not engaged in recommended mental-health therapy despite a borderline personality disorder diagnosis; she also had an ongoing history of being a victim of domestic violence.
Mother’s parental rights to two other children had previously been terminated in another state; B.T. was strongly bonded to a pre-adoptive foster mother where the child had lived since October 2015.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved under Iowa Code §232.116(1)(h) that the child could not be returned to the mother at the time of the termination hearing	Mother: she made significant progress and had completed necessary training; child could be returned	State: despite progress, mother lacked current knowledge/ability to meet child’s medical/feeding needs and had unresolved mental-health and domestic-violence issues	Court held clear and convincing evidence showed child could not be returned to mother at hearing; fourth element satisfied
Whether termination was in the child’s best interest under §232.116(2) and whether any exceptions under §232.116(3) applied	Mother: continued bond and progress weigh against termination	State: child needs permanency and stability; mother’s deficits create ongoing risk; no exception applies	Court held termination was in child’s best interest; no applicable exception proved

In re M.W., 876 N.W.2d 212 (Iowa 2016) (standard of review and focus on child’s best interests 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) (primary consideration is child’s best interests)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (urgency for permanency in TPR cases)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (courts should not delay permanency hoping a parent will improve)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (parental improvement cannot indefinitely postpone child’s need for permanency)
In re C.S., 776 N.W.2d 297 (Iowa Ct. App. 2009) (child’s rights can outweigh parental rights when permanency is at stake)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (parental inability to provide for long-term welfare undermines permanency)
In re C.K., 558 N.W.2d 170 (Iowa 1997) (keeping children in temporary foster care while parents ‘get their lives together’ is not in best interests)