In the Interest of I.G., D.G., and T.G., Minor Children, K.G., Mother, 17-1299

Mother K.G. has three children born 2012, 2013, and 2016; family came to DHS attention after domestic abuse by father and mother's arrest on May 31, 2016. Children were removed and placed in foster care after mother tested positive for methamphetamine.
Children adjudicated in need of assistance. Mother was inconsistent in services, unsuccessfully discharged from substance-abuse treatment, and intermittently engaged only around court dates. She was later diagnosed with major depressive disorder.
Mother made some improvements after the termination petition was filed (housing, employment, substance-abuse treatment progress), but remained inconsistent in mental-health treatment and other services; visits with mother reportedly produced adverse behaviors in the children.
The State petitioned to terminate parental rights on March 31, 2017; juvenile court terminated mother’s rights under Iowa Code § 232.116(1)(f) as to I.G. and § 232.116(1)(h) as to D.G. and T.G.
Juvenile court found mother’s improvement came late and was inconsistent, noted a pattern of progress only near court dates, and concluded returning the children would expose them to adjudicatory harm; termination was found to be in the children’s best interests.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mother)	Held
Sufficiency of evidence to terminate parental rights under § 232.116(1)(f) and (h) (inability to safely return children now)	Record shows mother’s substance abuse, inconsistent engagement in services, failed treatment, and pattern of episodic compliance; children cannot be safely returned now	Mother argues recent improvements show she can safely parent and that evidence is insufficient to find current inability to return children	Court affirmed termination: clear and convincing evidence supported finding children could not be safely returned due to substance abuse, mental-health issues, and unstable past performance
Whether termination is in the children’s best interests under § 232.116(2)	Best interest of children favors stability and safety; mother’s inconsistency and visits that worsen children’s behaviors weigh against reunification	Mother contends her recent stability and bond with children favor keeping parental rights	Court held termination is in children’s best interests given safety, need for stable long-term placement, and mother’s inability to meet needs consistently

In re D.W., 791 N.W.2d 703 (standards for de novo review in termination cases)
In re J.E., 723 N.W.2d 793 (clear-and-convincing evidence requirement in termination proceedings)
In re D.D., 653 N.W.2d 359 (definition of clear and convincing evidence)
In re L.L., 459 N.W.2d 489 (paramount concern is children’s best interests)
In re J.B.L., 844 N.W.2d 703 (affirmance may rest on any one proper statutory ground)
In re T.B., 604 N.W.2d 660 (future prospects may be inferred from past performance)
In re P.L., 778 N.W.2d 33 (factors for determining children’s best interests)