In the Interest of K.D.-c., and R.C., Minor Children, K.C., Mother, 17-0029

Mother used methamphetamine; older child R.C. ingested methamphetamine and was removed Oct 2015; mother tested positive for meth while pregnant with K.D.-C.; infant removed at discharge after birth Nov 2015.
Both children adjudicated children in need of assistance and placed with paternal grandparents.
DHS offered services (drug screens, treatment referrals, visitation) beginning Oct 2015; mother repeatedly missed screens or tested positive and admitted daily IV meth use as late as Oct 2016.
Mother’s last contact with children was July 2016; she declined further visitation until she stopped using drugs; by Dec 2016 her whereabouts were unknown.
District court terminated mother’s parental rights under multiple subsections of Iowa Code § 232.116(1); mother appealed alleging insufficient evidence and inadequate services.
Court of Appeals affirmed termination, relying on § 232.116(1)(h) (young children removed for at least six months and cannot be returned).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination under §232.116(1)(h)	Mother: evidence inadequate to show children cannot be returned now	State: mother’s continued substance use, failure to participate, unstable housing show children cannot be returned	Held: Affirmed; record shows mother failed to abstain and children cannot be returned
Whether DHS provided reasonable services to reunify family	Mother: services were inadequate to assist reunification	State: a host of services were offered; mother didn’t request additional services or engage	Held: Mother’s general complaints not preserved; services were adequate on record
Whether termination was in children’s best interests	Mother: (implicit) termination not appropriate given potential for reunification	State/guardian: children bonded with grandparents; instability and parental absence harm children	Held: District court’s best-interest finding affirmed
Whether mother preserved challenge to services on appeal	Mother: argues services insufficient on appeal	State: parent must demand needed services before termination hearing; issue not preserved	Held: Not preserved; parent bears responsibility to request services prior to hearing

In re D.W., 791 N.W.2d 703 (Iowa 2010) (appellate court may affirm termination on any sustained statutory ground)
In re H.S., 805 N.W.2d 737 (Iowa 2011) (scope of review for termination appeals is de novo)
In re C.H., 652 N.W.2d 144 (Iowa 2002) (parent must request needed services prior to termination hearing to preserve claim)