In the Interest of R.B., Minor Child, 21-0701

R.B., born April 2019, was removed from parental custody as an infant after both parents struggled with methamphetamine addiction and adjudicated a CINA.
Rodney (father) completed inpatient treatment and showed progress in 2019–Jan 2020, prompting a six-month permanency extension and later a 90‑day return‑home plan after a November 2020 review.
Shortly after the November permanency review, Rodney relapsed on methamphetamine and in December 2020 attempted suicide; he thereafter was inconsistent with treatment attendance and drug testing.
The State filed to terminate parental rights under Iowa Code § 232.116(1)(h) and (l). The juvenile court found insufficient clinical evidence to support (l) but concluded (h) was satisfied and termination served R.B.’s best interests.
The court emphasized Rodney had nearly two years to address substance‑abuse and mental‑health issues, but at the time of the hearing R.B. could not be safely returned to his custody. Rodney appealed; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination under § 232.116(1)(h) (child ≤3 removed ≥6 months and cannot be returned at present).	State: Rodney’s long history of substance abuse, recent relapse, mental‑health instability, and inconsistent compliance show R.B. cannot be safely returned now.	Rodney: He had made substantial progress and was on the verge of reunification; the relapse was a one‑time setback and does not show he cannot parent.	Held: Affirmed. Court found clear and convincing evidence under (h) that R.B. could not be returned at the time of the termination hearing.
Whether termination is in the child’s best interests under § 232.116(2).	State: Given safety and long‑term stability needs, termination better serves R.B.’s long‑range nurturing and growth despite bond with father.	Rodney: Strong bond and consistent visitation weigh against termination; seeks to resume custody.	Held: Affirmed. Court gave primary weight to child’s safety and long‑term needs; father’s inability to sustain sobriety and stability supported termination.

In re W.M., 957 N.W.2d 305 (Iowa 2021) (upholding termination where chronic substance abuse and relapses support inability to return child).
In re L.M., 904 N.W.2d 835 (Iowa 2017) ("present time" for returnability is the time of the termination hearing).
In re J.H., 952 N.W.2d 157 (Iowa 2020) (court may consider parent’s past performance in assessing future safety and stability).
In re A.S., 906 N.W.2d 467 (Iowa 2018) (standard of appellate review in termination cases and deference to juvenile court credibility findings).
In re L.H., 949 N.W.2d 268 (Iowa Ct. App. 2020) (paragraph (l) requires clinical diagnostic evidence of severe substance‑abuse disorder; lay assessments are insufficient).
In re J.C., 857 N.W.2d 495 (Iowa 2014) (best‑interest framework prioritizes child safety, placement for long‑term nurturing, and child’s physical/mental/emotional needs).