In the Interest of N.W., Minor Child, W.L.W., Father, 16-1548

Child N.W., born to unmarried parents, was removed from parental care in Nov 2015 after a history of mutual domestic violence and parental incapacity.
Father was arrested repeatedly (including for violating a no-contact order and domestic assault in Nebraska), jailed out-of-state for 88 days, then incarcerated in Iowa at time of the termination hearing; he had irregular supervised visits and failed to complete court-ordered services.
DHS caseworker provided limited services to the father while he was incarcerated out of state; the juvenile court later found aggravated circumstances and waived reasonable-efforts requirements.
State petitioned to terminate both parents’ rights in May 2016 under multiple subsections of Iowa Code § 232.116(1); father appeared by telephone at the termination hearing in Aug 2016.
At trial the court limited the father’s testimony about details of the Nebraska prosecution, allowing only a general assertion of innocence; the father appealed evidentiary rulings and the sufficiency/best-interest determinations.
The juvenile court terminated the father’s rights, citing multiple statutory grounds; the appeals court affirmed based on § 232.116(1)(h) and best-interest findings.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Father)	Held
Admissibility of evidence about Nebraska prosecution	Evidence of plea details is irrelevant to child-welfare issues; limit testimony	Father sought to show circumstances beyond his control prevented service completion; should be allowed to explain incarceration context	Court did not abuse discretion in limiting details; father could assert innocence but not relitigate criminal case
Sufficiency of statutory grounds for termination	Multiple grounds alleged; at least one must be proven by clear and convincing evidence	Father challenged all cited grounds	Affirmed under § 232.116(1)(h): child <3, CINA, out of home >6 months, cannot be returned without risk
Best-interest determination	Termination promotes child's safety, stability, and long-term welfare given domestic violence and lack of contact	Father argued kinship placement and sisters in Georgia favor preserving bond	Court found safety, stability, and lack of parental involvement outweighed kinship possibilities; termination best served child
Reasonable-efforts challenge	DHS waived efforts due to aggravated circumstances; reunification not required	Father argued DHS provided inadequate services while he was incarcerated	Father did not pursue a reasonable-efforts claim on appeal; court noted limited DHS efforts but upheld termination based on other factors

In re E.H. III, 578 N.W.2d 243 (Iowa 1998) (standard of review for evidentiary rulings)
In re M.M.S., 502 N.W.2d 4 (Iowa 1993) (incarceration does not automatically excuse parenting duties)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (best-interest factors in termination cases)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (de novo review of termination orders; clear-and-convincing standard)
In re S.J., 620 N.W.2d 522 (Iowa Ct. App. 2000) (considering arrests/incarceration in placement risk)
Marriage of Daniels, 568 N.W.2d 51 (Iowa Ct. App. 1997) (domestic abuse contrary to child’s best interests)