In the Interest of J.A. and M.K., Minor Children, K.S.K., Mother, 17-0606

Kathryn is mother of J.A. (born ~2014) and M.K. (born 2015); both adjudicated children in need of assistance (CINA) after concerns about domestic violence by father Johnnie and parental substance use.
J.A. was removed in 2014; family had on-and-off reunifications. M.K. remained briefly with Kathryn but both children were removed in May 2016 after Kathryn admitted near-daily methamphetamine use from Dec 2015–May 2016.
Kathryn participated intermittently in mental-health and substance-abuse treatment; had positive drug tests (sweat patch) for methamphetamine in 2016, missed multiple DHS drug tests, and had inconsistent therapy attendance after a violent incident with Johnnie.
Father Johnnie’s parental rights were terminated earlier; Kathryn maintained visitation that was affectionate and appropriate, worked as an LPN, and claimed ADHD medication caused some positive amphetamine results.
The State petitioned to terminate Kathryn’s parental rights in December 2016. The juvenile court terminated under Iowa Code § 232.116(1)(d) and (h); Kathryn appealed.

Issue	Kathryn's Argument	State's Argument	Held
Whether statutory grounds for termination under § 232.116(1)(d)/(h) were proved by clear and convincing evidence	Kathryn contends the State failed to show the circumstances leading to CINA continued despite services; she points to participation in services and recent return to treatment	The State contends Kathryn’s ongoing substance abuse, missed tests, positive methamphetamine results, and continued ties to an abusive father show circumstances persist and children cannot be safely returned	Court affirmed: clear and convincing evidence supports termination under § 232.116(1)(h) (children <3, adjudicated CINA, removed >6 months, cannot be returned safely)
Whether termination is in the children’s best interests	Kathryn emphasizes strong parent-child bond and positive visitation as reason to preserve parental rights	The State emphasizes child safety, stable foster placement with adoptive interest, and risks from Kathryn’s substance abuse and domestic-violence exposure	Court affirmed: termination is in best interests given safety risks and need for stable, nurturing placement

In re P.L., 778 N.W.2d 33 (Iowa 2010) (one proven statutory ground suffices to terminate parental rights)
In re M.W., 876 N.W.2d 212 (Iowa 2016) (standard of de novo review in termination appeals and clear-and-convincing evidence definition)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (affirming that termination requires clear and convincing evidence)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (parental denial of substance-abuse issues despite positive tests supports termination)
In re N.F., 579 N.W.2d 338 (Iowa Ct. App. 1998) (parent-child closeness is a mitigating factor but does not automatically outweigh other grounds)