In the Interest of H.B., Minor Child, 21-0615

Mother appealed the juvenile court's termination of her parental rights to H.B.; Court of Appeals reviewed the case de novo.
On appeal the mother contested only the best-interest determination, arguing termination would sever legal and familial ties and requesting placement via guardianship with H.B.’s maternal great aunt and uncle (who live in Texas).
The Interstate Compact on the Placement of Children (ICPC) study for the proposed Texas relatives was pending and incomplete at the time of the termination hearing; DHS learned of the relatives only three to four weeks before the hearing.
The mother has ongoing substance-abuse problems (including methamphetamine), had not completed substance-abuse treatment, and failed to engage in recommended mental-health services.
Mother’s visitation with H.B. was sporadic and often lacked meaningful interaction; visits were frequently led by the visitation supervisor rather than the mother.
The court affirmed termination, reasoning a guardianship was not shown appropriate (ICPC incomplete), guardianship is not generally preferable to termination, and maintaining parental ties was not in H.B.’s best interest; the court also noted a preservation issue on the guardianship argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination is in the child’s best interest versus ordering guardianship with maternal relatives	Mother: Termination would sever legal/familial ties; order guardianship with great aunt/uncle instead	State: ICPC pending so suitability unknown; guardianship is not generally preferable; mother’s substance abuse, lack of treatment/mental-health engagement, and inconsistent visitation make termination appropriate	Court affirmed termination: guardianship not shown appropriate (ICPC incomplete), guardianship is not a legally preferable alternative, and maintaining ties with mother was not in H.B.’s best interest
Whether the guardianship argument was preserved for appellate review	Mother: Raised guardianship alternative on appeal as best-interest ground	State: Argument was not presented to juvenile court and therefore not preserved	Court noted mother failed to preserve the preservation argument, but also rejected guardianship on the merits for independent reasons

In re Z.P., 948 N.W.2d 518 (Iowa 2020) (standard of appellate review for termination proceedings)
In re T.S., 868 N.W.2d 425 (Iowa Ct. App. 2015) (clarifies clear-and-convincing evidence standard in termination cases)
In re A.S., 906 N.W.2d 467 (Iowa 2018) (sets out the three-step analysis for termination and notes guardianship is generally not preferable)
In re B.T., 894 N.W.2d 29 (Iowa Ct. App. 2017) (reiterates that guardianship is not a legally preferable alternative to termination)