In the Interest of H.S. And S.N., Minor Children, V.R., Mother, 2011 Iowa Sup. LEXIS 66

Valarie (mother) is parent of S.N. (born 2003) and H.S. (born 2007); Steven is father of S.N. and Charles is father of H.S.
H.S. sustained injuries during a visit; DHS found Tony (Valarie’s husband) as perpetrator; Valarie initially denied but later conceded Tony’s abuse.
Children were removed and adjudicated CINA; custody placed with fathers Steven (S.N.) and Charles (H.S.) with supervised visits for Valarie.
During 2010–2011, Valarie and Tony’s relationship and pregnancy were central to questions about stability and safety; Valarie’s conduct included deception about contact and pregnancy.
Juvenile court terminated Valarie’s parental rights to both children; Court of Appeals reversed as to H.S. but affirmed as to S.N.; Supreme Court granted review to address whether loss of child support matters in best interests under Iowa Code § 232.116(2).
Court ultimately held that termination was in the children’s best interests and that anticipated loss of child support should not affect the § 232.116(2) analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether loss of child support can affect best interests under § 232.116(2)	Valarie: loss of support is relevant to well-being	State/Charles: best interests focus on safety and permanence, not support	Loss of support not a factor in § 232.116(2) analysis
Timeliness of Steven’s request for further review	Steven timely joined timeline per rules	Steven’s joinder was untimely; finality attached	Steven’s late joinder did not preserve his challenge; court affirms as to S.N.
Standard of review for termination of parental rights	Clear grounds established; de novo review preferred	Court should defer to juvenile court’s findings on credibility	Terminations reviewed de novo with weight to juvenile court findings
How 232.116(2) best interests framework applies to financial considerations	Financial support should be relevant to best interests	Financial factors not to be weighed against safety and permanence	Best interests focus on safety, long-term nurturing, and needs, excluding direct financial support as a weighing factor

In re L.S., 483 N.W.2d 836 (Iowa 1992), 483 N.W.2d 836 (Iowa 1992) (loss of child support not to derail termination when best interests require)
In re M.S., 519 N.W.2d 398 (Iowa 1994), 519 N.W.2d 398 (Iowa 1994) (focus on child’s long-term safety and needs over financial considerations)
P.L., 778 N.W.2d 33 (Iowa 2010), 778 N.W.2d 33 (Iowa 2010) (advises applying § 232.116(2) framework with specific reasons)
In re J.E., 723 N.W.2d 793 (Iowa 2006), 723 N.W.2d 793 (Iowa 2006) (clarifies § 232.116(2) framework and safety emphasis)
In re K.M., 653 N.W.2d 602 (Iowa 2002), 653 N.W.2d 602 (Iowa 2002) (discusses best interests and safety emphasis in termination)
In re Goettsche, 311 N.W.2d 104 (Iowa 1981), 311 N.W.2d 104 (Iowa 1981) (recognizes financial responsibility as relevant in some contexts)
Peppmeier v. Murphy, 708 N.W.2d 57 (Iowa 2005), 708 N.W.2d 57 (Iowa 2005) (discusses finality and joinder issues in further review)