In the Interest of S.G. and J.G.-p., Minor Children, S.P., Mother, 17-0157

DHS involvement began in 2011 when mother (then 16) had delinquency adjudication; children J.G.-P. (b.2010) and S.G. (b.2012) later adjudicated CINA in Oct. 2012.
Mother intermittently engaged in services (housing, GED work, parenting) but showed long-standing instability: job losses, missed visits, poor communication with providers, and inconsistent therapy participation.
Children were removed Aug. 12, 2014 after mother relocated to California without notifying DHS and later again Feb. 16, 2016 after safety concerns (unapproved male in home; children reported being frightened).
Mother had periodic progress (Oct. 2015), prompting extended reunification efforts, but subsequently regressed: quit education, multiple job losses, refused drug testing, failed to take children to therapy/daycare, and permitted a man in her home contrary to court expectations.
Termination petition filed June 2016; hearing over three days in 2016. Juvenile court terminated mother’s parental rights under Iowa Code § 232.116(1)(e) and (f). Mother appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory ground for termination under §232.116(1)(f) was proved (children could not be returned at time of hearing)	State: children had been removed for statutory period, mother lacked stability and protective capacity; trial home visits failed; children’s needs unmet	Mother: she had made progress, bonded with children, capable of reunification	Court affirmed §232.116(1)(f): clear and convincing evidence children could not be returned; limitations period and ongoing instability dispositive
Whether termination is in children’s best interests under §232.116(2)	State: children attached to foster parents, need permanency and safety outweigh bond to mother	Mother: strong bond; should preserve parental rights	Court held termination was in children’s best interests—children had attachments and permanence with foster family and mother could not provide stability
Whether permissive factors in §232.116(3) counsel against termination	State: none compelling	Mother: did not press specific statutory exceptions	Court found no compelling permissive factors to avoid termination
Whether procedural or evidentiary errors warranted reversal	Mother: contested sufficiency of evidence and factual findings	State: evidence supports findings; de novo review still affirms	Court affirmed findings and termination after de novo review

In re D.W., 791 N.W.2d 703 (Iowa 2010) (standard of review for termination is de novo)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (proof children cannot be returned at time of termination hearing)
In re J.E., 723 N.W.2d 793 (Iowa 2006) (primary consideration: child safety and need for permanent home)
In re A.M., 843 N.W.2d 100 (Iowa 2014) (permissive factors in §232.116(3) are discretionary)
In re P.L., 778 N.W.2d 33 (Iowa 2010) (court must consider permissive factors before terminating parental rights)