In the Interest of H.L., Minor Child, M.L., Mother, S.L., Father, 17-0357

H.L., born March 2016, required intensive neonatal care and was removed from parents four days after birth; adjudicated CINA and placed in foster care.
Mother (Mercedes) had prior terminations of parental rights to two older children after severe abuse; parents lived unstably, moved frequently, lacked steady employment, and had untreated mental-health issues.
Both parents tested positive for methamphetamine during the CINA case and reported domestic violence belatedly; they nonetheless maintained regular supervised visits and formed bonds with H.L.
The State petitioned to terminate parental rights in October 2016; hearings occurred January 6 and February 17, 2017; both parents were incarcerated on the second hearing day.
Juvenile court terminated Mercedes under Iowa Code § 232.116(1)(g) and both parents under § 232.116(1)(h); parents appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of continuance (father)	Steve: Court abused discretion; counsel unprepared and separation from Mercedes required more time	State/GAL: No prejudice; hearing had been scheduled months; separation not critical	No abuse of discretion; no demonstrated injustice or prejudice
Reasonable efforts / supervised visitation (father)	Steve: DHS failed to make reasonable reunification efforts by refusing unsupervised visits	DHS: Parents were unstable, undisclosed living situations, and untrustworthy for unsupervised visits	DHS satisfied reasonable-efforts standard; supervised visits appropriate for child’s safety
Request for six-month permanency extension (father)	Steve: Needs more time; signs of potential improvement	State/GAL: Father showed little progress, ongoing substance use, incarceration, no stable housing	Court did not err denying extension; delay would harm child’s permanency interests
Closeness of parent-child relationship / best interests (both)	Parents: Strong attachment to H.L.; termination would be detrimental	State/GAL: Child bonded to foster parents and needs stability; parents unsteady and failed services	Termination not detrimental given foster-home stability; adoption serves child’s best interests

In re M.W., 876 N.W.2d 212 (Iowa 2016) (standard of review for termination appeals)
In re L.G., 532 N.W.2d 478 (Iowa Ct. App. 1995) (scope of de novo review in juvenile matters)
In re B.B., 826 N.W.2d 425 (Iowa 2013) (clear-and-convincing evidence standard explained)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (evidentiary standard discussions in termination cases)
In re R.B., 832 N.W.2d 375 (Iowa Ct. App. 2013) (continuance abuse-of-discretion standard)
In re C.W., 554 N.W.2d 279 (Iowa Ct. App. 1996) (prejudice requirement to reverse continuance denial)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (DHS reasonable-efforts obligation not absolute and affects burden)
In re A.A.G., 708 N.W.2d 85 (Iowa Ct. App. 2005) (parents must request more services and courts weigh child’s time in proceedings)
In re M.B., 553 N.W.2d 343 (Iowa Ct. App. 1996) (visitation controlled by child’s best interests)
In re A.M., 843 N.W.2d 100 (Iowa 2014) (termination despite parent-child bond when child’s permanency and stability favor adoption)
In re S.R., 600 N.W.2d 63 (Iowa Ct. App. 1999) (affirmance requires only one valid statutory ground)
Hyler v. Garner, 548 N.W.2d 864 (Iowa 1996) (appellate review confined to issues raised by appellant)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (best-interests analysis centers on child’s safety and long-term needs)