In the Interest of R.L., X.L., and A.L., Minor Children, 21-1789

DHS became involved after the mother tested positive for methamphetamine and was suspected of illegal drug use; children adjudicated CINA and removed.
Three children (ages 17, 13, 11) were placed with the father of the younger two; mother had identified substance‑abuse and mental‑health issues.
Mother received services and the court granted a six‑month extension for reunification efforts under Iowa Code § 232.104(2)(b).
During the extension and leading up to the termination hearing the mother largely failed to comply: she evaded drug tests for ~10 months, was discharged from treatment for nonattendance, only completed late evaluations, and never progressed beyond supervised visits.
The State filed petitions to terminate the mother’s parental rights under Iowa Code § 232.116(1)(e) and (f); the juvenile court granted termination and the mother appealed, asserting the § 232.116(3)(c) exception should have barred termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 232.116(3)(c) (closeness-of-relationship exception) applies	Mother: termination would be detrimental due to close parent‑child bonds	State: no clear and convincing evidence of such closeness or detriment	Held: mother failed to prove exception by clear and convincing evidence; exception not applied
Whether statutory grounds under § 232.116(1)(e) and (f) were met	Mother: did not substantially contest grounds on appeal	State: grounds proven by record of removal, lack of progress, and noncompliance	Held: grounds for termination were established and affirmed
Whether mother preserved/challenged refusal to defer permanency (additional time)	Mother: trial court erred by refusing further time/deferral (argued in appeal papers)	State: issue not raised below and/or insufficiently developed on appeal	Held: claim not preserved for review or insufficiently developed; court declined to address it

In re A.S., 906 N.W.2d 467 (Iowa 2018) (three‑step TPR review; parent bears burden to prove exceptions)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (reciting the three‑step termination analysis)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issues must be raised and decided below to be reviewed on appeal)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (appellate courts will not assume counsel’s research/advocacy; arguments must be developed)
Inghram v. Dairyland Mut. Ins. Co., 215 N.W.2d 239 (Iowa 1974) (appellate courts refuse to assume partisan advocacy for appellant)
Hyler v. Garner, 548 N.W.2d 864 (Iowa 1996) (insufficiently developed appellate issues will not be decided)