In the Interest of J.S. & N.S., Minor Children, A.S., Mother, 846 N.W.2d 36

Mother Ashley admitted to active methamphetamine addiction with multiple positive drug tests, relapses, and prior child removals in Nebraska; she later entered inpatient treatment.
DHS received reports she used meth while caring for her children; children spent substantial time with their maternal grandmother, who supervised visits and provided stable care.
DHS alleged N.S. (9) and J.S. (5) were CINA under multiple provisions including §232.2(6)(c)(2) (harmful effects from lack of supervision) and §232.2(6)(g) (imminently likely to abuse or neglect causing physical injury).
Juvenile court adjudicated the children CINA under §232.2(6)(a), (b), and (c)(2) but declined under §232.2(6)(g); State appealed only the §232.2(6)(g) adjudication and record consisted of stipulated exhibits (no live testimony).
Court of appeals reversed the §232.2(6)(g) adjudication; Iowa Supreme Court affirmed the court of appeals, holding meth addiction alone does not establish an imminent likelihood of nonaccidental physical injury when mitigating facts (available caregiver, children currently cared for) exist.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether parent’s methamphetamine addiction alone supports CINA adjudication under §232.2(6)(g) (imminently likely to abuse or neglect causing physical injury)	State: Ashley’s active, repeated drug use, positive tests, erratic behavior, history of removals, and expert-based assertions about meth’s effects establish imminent risk of physical injury	Ashley: Addiction alone, with children cared for by grandmother and no prior physical injury, is insufficient to show imminent physical harm	Court: Reversed juvenile court as addiction alone insufficient for §232.2(6)(g); affirmed CINA under §232.2(6)(c)(2) (harmful effects from neglect of supervision)

State v. Petithory, 702 N.W.2d 854 (Iowa 2005) (expert testimony on methamphetamine dangers used to support criminal neglect finding)
In re D.D., 653 N.W.2d 359 (Iowa 2002) (prior sexual misconduct supported finding a child was imminently likely to be sexually abused)
In re A.M.H., 516 N.W.2d 867 (Iowa 1994) (history of physical/sexual abuse by caregivers supported imminent risk adjudication)
In re B.B., 440 N.W.2d 594 (Iowa 1989) (physical injury prerequisite for past-abuse adjudication; harmful effects standard explained)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (severe, chronic drug addiction can render a parent unfit)
In re L.L., 459 N.W.2d 489 (Iowa 1990) (child-protection statutes are preventive and do not require harm to occur before intervention)
State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (definition of “imminent” as "ready to take place" adopted)
State v. Lane, 743 N.W.2d 178 (Iowa 2007) ("imminent" means impending or about to occur)
In re Wall, 295 N.W.2d 455 (Iowa 1980) ("harmful effects" pertains to physical, mental, or social welfare of a child)