In the Interest of K.M., Minor Child, R.M., Mother, 17-0079

May 2015 DHS investigated after the child sustained an injury near the right eye when the mother threw a water bottle in anger.
A week earlier the mother reportedly threw a box at the child causing a bruise; child was born in 2011.
In July 2015 the child was adjudicated a CINA and removed from the mother’s custody in May 2015, with no trial re-uptreatment period.
In January 2017 the juvenile court terminated the mother’s parental rights under Iowa Code §232.116(1)(f).
The mother asserted DHS failed to make reasonable reunification efforts and that the child could not be returned at the time of termination.
The child was placed with a foster family who wished to adopt, supporting permanency and stability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 232.116(1)(f) grounds were proven	State contends grounds proven	Mother argues not proven	Grounds proven; termination affirmed
Whether reasonable reunification efforts were proved	State argues reasonable efforts shown	Mother argues efforts were insufficient	Reasonable efforts proven; termination affirmed

In re M.W., 876 N.W.2d 212 (Iowa 2016) (de novo review; credibility weighs in assessing the record)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (reasonable efforts required to show child cannot be safely returned)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (urgency and permanency considerations in termination)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (permanency rights of child exceed parental rights after grounds proven)
In re C.S., 776 N.W.2d 297 (Iowa Ct. App. 2009) (child’s best interests require permanency over prolonged temporary placements)