In the Interest of B.H., Minor Child, A.K., Mother, L.H., Father, 17-1190

B.H., born 2008, was removed from parents A.K. (mother) and L.H. (father) in 2015 after safety concerns (mother passed out while high at a pool); child placed with maternal grandmother and later foster care.
Both parents have long histories of mental-health issues, substance abuse, and criminal records; father had not had contact for years and had threatened family and caseworkers, producing no-contact orders and contempt proceedings.
Parents were offered reunification services; father intermittently engaged in treatment but repeatedly made violent threats, undermining progress; mother had unstable housing, incarceration, and sporadic contact with the child.
The juvenile court found the child could not be returned and initiated termination proceedings; after hearings and admitted provider reports, the court terminated both parents’ parental rights; both appealed.
On de novo review the Court of Appeals affirmed, finding reasonable efforts by the State, admissibility of provider reports under chapter 232 exceptions, statutory grounds for termination, and termination was in the child’s best interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether State made reasonable efforts for reunification	State: offered services, evaluations, counsel, and treatment opportunities	Parents: challenged adequacy of efforts (father argued insufficient efforts)	Held: State provided reasonable efforts to both parents
Admissibility of provider reports and emails at TPR hearing	State: reports admissible under Iowa Code §232.96(6) and chapter 232 evidentiary liberalization	Father: objected for lack of foundation and hearsay	Held: Reports and email properly admitted; exceptions allow such evidence in juvenile cases
Whether statutory grounds for termination were proved (Iowa Code §232.116(1)(f))	State: child could not be returned safely at time of hearing due to unresolved parental issues and threats	Parents: contested that conditions were corrected or that termination was premature	Held: Clear and convincing evidence showed child could not be returned; ground proven
Whether termination is in child’s best interests and whether extensions were warranted	State: permanency and child safety require termination rather than delay	Mother: asked for 3–6 month extension to attempt reunification	Held: Termination serves child’s need for permanency; extension denied

In re D.W., 791 N.W.2d 703 (Iowa 2010) (standard of de novo review for TPR appeals)
In re M.W., 876 N.W.2d 212 (Iowa 2016) (three-part framework for TPR: grounds, best interests, exceptions)
In re N.N., 692 N.W.2d 51 (Iowa Ct. App. 2004) (admission of Department/provider reports under juvenile evidence exception)
In re A.M., 856 N.W.2d 365 (Iowa 2014) (chapter 232 evidentiary liberalization and child-welfare focus)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (limits on delaying permanency when statutory grounds for TPR are met)