In the Interest of M.H. and V.H., Minor Children, K.H., Father, A.H., Mother, 16-1238

Father filed to terminate mother's parental rights to two children (ages 6 and 7); district court terminated under Iowa Code § 600A.8(3)(b) and (9); mother appeals only the (3)(b) ground.
Between Aug. 2012 and Sept. 2015 mother amassed numerous criminal convictions and arrests (approx. 11 convictions, ~15 jail stays totaling ~360 days); admitted methamphetamine possession and had incidents of intoxication and violence.
In Aug. 2012 mother, while intoxicated, drove a vehicle and ran over the father’s foot; she later received a suspended sentence that was ultimately imposed after probation violations.
Mother had largely been absent from the children’s lives: last in-person contact Dec. 25, 2013; last phone contact Sept. 23, 2014; limited and inconsistent visitation before that due to incarcerations and other conduct.
Guardian ad litem reported children did not want contact with mother and recommended termination based on safety concerns (violence, substance abuse, criminal history); children were doing well in father’s custody.

Issue	Petitioner's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination under § 600A.8(3)(b) (abandonment)	Father: mother abandoned children by failing to maintain substantial and continuous/repeated contact, support, or visits.	Mother: challenges sufficiency of evidence that she maintained no substantial/continuous contact; blames father for restricting access and contends she attempted to pursue custody.	Court affirmed termination — abandonment standard met; mother waived challenge to § 600A.8(9) and (9) independently supported termination.
Whether termination is in children’s best interests	Father: children are safe and thriving with him; mother’s history makes reunification unsafe.	Mother: argued for preservation of parental rights (implicit) and blamed father for limiting contact.	Court held termination is in children’s best interests given mother’s criminal history, substance use, instability, lack of contact, and GAL recommendation.

In re C.A.V., 787 N.W.2d 96 (Iowa Ct. App. 2010) (standard of de novo review in termination proceedings)
In re G.A., 826 N.W.2d 125 (Iowa Ct. App. 2012) (deference to district court factual findings, including credibility)
Hyler v. Garner, 548 N.W.2d 864 (Iowa 1996) (appellant must identify alleged error on appeal)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (appellant’s burden to specify error; review confined to issues raised)
In re Voeltz, 271 N.W.2d 719 (Iowa 1978) (if any statutory ground for termination proven by clear and convincing evidence, termination will be upheld)
In re J.L.W., 523 N.W.2d 622 (Iowa Ct. App. 1994) (best-interest inquiry follows finding of statutory ground)