In the Interest of D.N. and N.N., Minor Children, L.S., Mother, 17-0849

Mother appealed termination of parental rights to two children: D.N. (b. 2010) and N.N. (b. 2016).
Longstanding DHS involvement: prior CINA adjudication (2013) and earlier termination of rights to three older children for substance abuse/mental-health issues.
Children removed April 2016 for parents' continued drug use, mental-health problems, and violations of safety plan; adjudicated CINA June 2016 and remained out of home.
Mother has repeated relapses and over a decade of failed substance-abuse treatment (15 programs); limited sobriety only while in inpatient treatment at time of termination hearing.
Mother refused meaningful mental-health treatment, lacked stable housing and employment, and was inconsistent in visits; court found D.N. shared a bond with mother but N.N. did not.
Juvenile court terminated parental rights under Iowa Code §232.116(1)(l) (both children), (f) (D.N.), and (h) (N.N.); mother sought six-month extension but trial court denied; appellate court affirmed.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (State)	Held
Whether termination is contrary to children's best interests because of parent-child bond	Mother: strong bond with children (especially D.N.) makes termination detrimental	State: child's need for permanency, mother's chronic relapse and instability outweigh bond	Court: Termination is in children’s best interests; bond insufficient to bar termination given risk of prolonged instability
Whether court should grant a six-month extension for reunification	Mother: needs more time to maintain sobriety and complete treatment	State: mother’s longstanding failures and prior terminations mean additional time unlikely to eliminate need for removal	Court: Denied extension — not persuaded removal need would end in six months; children’s need for permanency prevails

In re M.W., 876 N.W.2d 212 (Iowa 2016) (standard of de novo review in TPR appeals)
In re A.M., 843 N.W.2d 100 (Iowa 2014) (weight given to juvenile court factual findings and credibility)
In re J.E., 723 N.W.2d 793 (Iowa 2006) (primary consideration is child's best interests)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (past parental performance informs future care capacity)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (insight from parent's past performance)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (court need not address unchallenged statutory grounds)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (children require permanency and stability)
In re C.K., 558 N.W.2d 170 (Iowa 1997) (not in child's best interests to remain indefinitely in temporary care)
In re C.S., 776 N.W.2d 297 (Iowa Ct. App. 2009) (children’s rights to permanency can outweigh parents’ needs)