In the Interest of N.N., Minor Child, 21-1978

Child N.N., born 2016; both mother and father appealed termination of parental rights.
Juvenile court terminated parental rights under Iowa Code §232.116(1)(f) and (l) and ordered adoption-related dispositional relief.
Mother suffered life‑threatening car accident and brain trauma; at the termination hearing she remained hospitalized, unable to communicate or care for herself.
Father has ongoing substance‑abuse and criminal issues; court found him unsafe to be around the child.
Mother challenged only paragraph (f) of §232.116(1) and requested a six‑month reunification extension but failed to raise the extension request in juvenile court.
Both parents urged the permissive exception in §232.116(3)(c) (harm from severing a close parent–child bond); the court and this panel declined to apply it because neither parent was able or qualified to care for the child and the child needed permanency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory ground §232.116(1)(f) (child cannot be returned at time of hearing) was proven	State: mother was hospitalized and unable to care for child at hearing; grounds proven.	Mother: challenges only the fourth element — that child could not be returned at hearing.	Affirmed: clear and convincing evidence mother could not care for child at hearing; ground proven.
Whether mother was entitled to a six‑month extension before termination	State: no extension warranted; mother’s uncertain prognosis and lack of concrete, time‑limited steps made extension inappropriate.	Mother: requested six‑month extension to achieve reunification.	Not preserved on appeal; even if preserved, record would not support extension because no specific, likely timeline for mother's ability to parent.
Whether §232.116(3)(c) permissive exception (detriment from severing bond) should bar termination	State: exception is permissive and not supported — parents are unqualified and child needs permanency.	Parents: argued a close bond exists and termination would be detrimental.	Denied: parents unfit (mother’s incapacitation; father’s substance/criminality); child’s need for permanency outweighs potential detriment.

In re Z.P., 948 N.W.2d 518 (Iowa 2020) (standard of review for termination proceedings)
In re T.S., 868 N.W.2d 425 (Iowa Ct. App. 2015) (clear‑and‑convincing evidence standard explained)
In re A.S., 906 N.W.2d 467 (Iowa 2018) (three‑step framework for termination review)
In re A.R., 932 N.W.2d 588 (Iowa Ct. App. 2019) (§232.116(3) exceptions are permissive)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (focus on parent's sobriety and ability to provide for child when assessing exceptions)