In the Interest of J.c, Minor Child. D.C., Father, 2014 Iowa Sup. LEXIS 116

J.C. born 2010 to Khrista, who was imprisoned; Daniel became J.C.'s established husband/father despite not being biological or adoptive father.
DHS became involved over concerns of methamphetamine use; J.C. temporarily placed with Daniel.
Paternity disputes: Robert later established as biological father; Daniel began with CINA proceedings.
Guardians ad litem moved to determine paternity, seeking to designate Robert as the father in CINA.
Juvenile court concluded Daniel was not a necessary party under §232.91(1) and dismissed him; GAL and State appealed.
Court of Appeals reversed, finding literal interpretation leads to absurd results; Supreme Court vacated and affirmed juvenile court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is an established father a parent under §232.91(1)?	GAL/State: Daniel is J.C.'s established father and thus a parent.	Daniel: established fathers should be treated as parents.	No; established father is not a statutory parent under §232.2(39); not a necessary party.
Is Daniel a necessary party in termination proceedings after paternity was fixed for Robert?	Daniel should remain a party since he has standing as established father.	Daniel not a parent; not a guardian/custodian/guardian ad litem; not necessary.	Daniel not a necessary party to termination proceedings; dismissal affirmed.

Callender v. Sidles, 591 N.W.2d 182 (Iowa 1999) (due process rights of biological parents; standing to challenge paternity)
In re B.G.C., 496 N.W.2d 239 (Iowa 1992) (authority to determine biological paternity in termination contexts)
In re A.C., 415 N.W.2d 609 (Iowa 1987) (child welfare proceedings expedited for best interests)
Gartner v. Iowa Dep’t of Pub. Health, 830 N.W.2d 335 (Iowa 2013) (presumption of paternity and rights of presumptive parent)
J.R., 315 N.W.2d 750 (Iowa 1982) (intervention rights based on interest, not necessity)