In the Interest of J.C., Minor Child, 21-0949

J.C., born July 2018, suffered serious head/retinal injuries while in parents' care; doctors diagnosed abusive head trauma after November 2018 hospitalization. DHS issued a founded abuse assessment and the child was removed on November 30, 2018.
Juvenile court adjudicated the child in need of assistance (Aug. 22, 2019) and returned the child to mother (Nov. 8, 2019) while noting concerns about the mother’s honesty regarding the injuries.
Less than three months after return, on Jan. 28, 2020, the child was rehospitalized with retinal hemorrhages, bruising, and a possible healed arm fracture; the child was removed again (Jan. 31, 2020).
Medical testimony consistently attributed the injuries to physical trauma; the mother denied causing or knowing the source of trauma and offered alternative theories (crib fall, illness, perinatal oxygen issues) that the court found unpersuasive.
The child spent more than 24 months in foster care with no recurrence of retinal hemorrhaging; juvenile court terminated the mother’s parental rights under Iowa Code §232.116(1)(h). The mother appealed; the Court of Appeals affirmed.

Issue	Mother’s Argument	State’s Argument	Held
Whether §232.116(1)(h) was satisfied (specifically that child cannot be safely returned at the time of the hearing)	Mother says she has appropriate housing and parenting skills and challenges the fourth element	Repeated traumatic injuries while child was in mother’s care, mother won’t identify source of trauma, child would be unsafe if returned	Affirmed — clear and convincing evidence child could not be returned at the time of the hearing
Whether termination is in child’s best interests and whether a parent–child bond precludes termination (§232.116(2) & (3)(c))	Mother stresses a strong bond with child	Safety risk from unresolved source of serious trauma outweighs bond	Affirmed — termination is in child’s best interests; bond does not preclude termination
Whether guardianship is a legally preferable alternative to termination	Mother requests guardianship instead of termination	State argues guardianship is not legally preferable given safety concerns and precedent	Denied — guardianship not appropriate; termination affirmed
Sufficiency of mother’s alternative causation theories for injuries	Mother proffers crib fall, illness, or perinatal oxygen issues as possible causes	Medical evidence and foster care record support trauma etiology; alternate theories unpersuasive	Court rejected maternal causation theories as insufficient to rebut trauma findings

In re W.M., 957 N.W.2d 305 (Iowa 2021) (standard of de novo review in termination appeals)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (three-step framework for reviewing termination: statutory ground, best interests, permissive factors)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (interpretation of "at the present time" as the time of the termination hearing)
In re A.S., 906 N.W.2d 467 (Iowa 2018) (guardianship is not a legally preferable alternative to termination)
In re B.T., 894 N.W.2d 29 (Iowa Ct. App. 2017) (discussing guardianship versus termination alternatives)