In the Interest of J.L., Minor Child, V.L., Mother, 868 N.W.2d 462

Mother, born deaf and primarily sign-language user, gave birth in 2014; hospital involved public agencies after postpartum mental-health concerns.
Department of Human Services (DHS) provided extended "safety services" but did not retain an American Sign Language (ASL) interpreter, communicating largely by written notes.
The State filed a child-in-need-of-assistance petition when the child was one month old; child removed from mother at two months; juvenile court ordered an interpreter for the removal hearing but DHS did not provide ongoing interpretive services for several months.
DHS first provided an interpreter only shortly before a delayed adjudicatory hearing; DHS and visitation supervisors acknowledged written communication was often inadequate and that interpreters would have been helpful.
The State later filed to terminate parental rights when child was seven months old; juvenile court terminated rights, finding DHS made reasonable efforts; mother appealed claiming DHS failed its statutory reasonable-efforts duty by not providing timely interpreter services.
Iowa Court of Appeals reversed termination, holding DHS failed to make reasonable efforts to facilitate reunification by not furnishing interpreter services for approximately half the agency involvement period, and remanded to dismiss the termination petition under Iowa Code § 232.117(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DHS made reasonable efforts to reunify by providing interpreter services	Mother: DHS knew she was hearing-impaired and sign-language dependent; DHS failed to provide timely ASL interpreters, impeding reunification	DHS: Rural access issues made interpreter provision difficult; written notes sufficed; interpreters were provided later and barriers mainly due to mother’s choices	Held: DHS did not satisfy statutory reasonable-efforts obligation; failure to provide timely interpreter services required reversal of termination
Whether mother’s posttrial motion tolled appeal time	Mother: Motion challenged court’s reliance on an unpled statutory ground and sought correction	State: Motion was vague/meritless and should not toll appeal deadline	Held: Motion was proper and tolled appeal time; appellate court had jurisdiction
Whether court may rely on an unpled statutory ground to terminate rights	Mother: Court improperly relied on unpled ground in termination order	State: Other alleged statutory ground supported termination	Held: Juvenile court corrected the error after new-trial motion; appellate review proceeded on remaining alleged ground
Whether ADA claim must be decided to resolve appeal	Mother: DHS’s failure to provide interpreter also violated ADA	State: ADA not necessary; termination statute controls	Held: Court did not reach ADA issue because statutory reasonable-efforts failure resolved the appeal

In re C.B., 611 N.W.2d 489 (Iowa 2000) (reasonable-efforts requirement central to reunification analysis)
Iowa Elec. Light & Power Co. v. Lagle, 430 N.W.2d 393 (Iowa 1988) (court may consider substance over label of posttrial motions)
Sierra Club Iowa Chapter v. Iowa Dep’t of Transp., 832 N.W.2d 636 (Iowa 2013) (posttrial motion tolled appeal period when raising legal issues tied to factual matters)
In re Estate of Hord, 836 N.W.2d 1 (Iowa 2013) (discussing tolling of appeal deadlines by posttrial motions)
In re Torrance P., 522 N.W.2d 243 (Wis. Ct. App. 1994) (discussing interaction between termination statutes and ADA accommodations)
J.H. v. State, Dep’t of Health & Soc. Servs., 30 P.3d 79 (Alaska 2001) (equating statutory reasonable-efforts duty with ADA accommodation requirement)
In re Doe, 60 P.3d 285 (Haw. 2002) (refusing ADA as a TPR defense but noting accommodation obligations inform reasonable-efforts inquiry)
In re Terry, 610 N.W.2d 563 (Mich. Ct. App. 2000) (finding consistency between statutory reasonable-efforts and ADA reasonable-accommodation requirements)