In the Interest of L.T., A.T., and D.T., Minor Children, 924 N.W.2d 521

Background

Mother K.T.'s three children were adjudicated children in need of assistance after parental methamphetamine use; children placed in foster care in Sept. 2015.
The State petitioned to terminate parental rights in June 2016; a termination hearing occurred in November 2016.
The juvenile court orally announced in May 2017 that it would grant the State's petition, but did not issue a written termination order for ~20 months.
DHS reopened the record for the State in May 2017 and the court accepted updated reports; the mother later sought to reopen the record and to show sobriety, stable housing, and employment.
During the 20-month delay the mother requested continued reasonable-efforts services; DHS largely ceased providing reunification services after the court’s oral statement.
On July 27, 2018 the juvenile court entered a written order terminating K.T.’s parental rights and denied her motions to reopen; the Iowa Supreme Court reversed and remanded.

Issues

Issue	Plaintiff's Argument (K.T.)	Defendant's Argument (State/DHS)	Held
Whether court abused discretion by denying mother’s motion to reopen the record after a 20‑month delay	K.T. argued the long delay made the November 2016 record stale and she should be allowed to introduce recent evidence of sobriety, housing, and employment	State pointed to the November 2016 evidence and argued reopening was discretionary and unnecessary	Court: Abuse of discretion; remand to reopen the record and receive mother’s evidence before ruling on termination
Whether DHS could stop providing reasonable efforts toward reunification after the court’s oral announcement but before a written order	K.T. argued reasonable efforts must continue until a final written termination order and DHS improperly halted reunification services	State argued further services would be pointless given the court’s clear oral intention to terminate	Court: Reasonable-efforts obligation continues until a final written order (or court waiver); but obligation may not require reunification if child’s safety/ permanency favor other actions; DHS’s efforts during the hiatus must be considered on remand
Whether the juvenile court’s inordinate delay rendered its findings stale for termination purposes	K.T. argued the delay undermined reliability of findings and warranted reopening/ reversal	State argued oral ruling reflected the facts and delay did not require reversal	Court: Delay was inordinate; because of delay and mother’s timely request to present new, germane evidence, reversal and remand were required
Remedy and next steps	K.T. sought reopening, consideration of new evidence, and fresh adjudication	State sought to affirm termination order as reflecting prior findings	Court: Vacated court of appeals decision, reversed juvenile court’s termination order, instructed juvenile court to reopen record, receive new evidence expeditiously, consider DHS’s efforts, and promptly issue a written order

Key Cases Cited

In re A.S., 906 N.W.2d 467 (Iowa 2018) (standard of review in termination proceedings)
In re J.R.H., 358 N.W.2d 311 (Iowa 1984) (trial court’s reopening of record reviewed for abuse of discretion)
In re J.E., 723 N.W.2d 793 (Iowa 2006) (importance of prompt permanency decisions and shift toward child’s best interests)
In re T.R., 705 N.W.2d 6 (Iowa 2005) (delay in termination cases undermines finality; oral statements are not final orders)
DeKruyff v. Johnston, 252 N.W.2d 389 (Iowa 1977) (oral intent of court is not a final appealable ruling)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (reasonable-efforts requirement as part of State’s proof)
In re L.M., 904 N.W.2d 835 (Iowa 2017) (State must show reasonable efforts when termination grounds invoke that requirement)
In re K.M., 653 N.W.2d 602 (Iowa 2002) (focus on child’s best interests and safety in termination analysis)