In the Interest of S.W., Minor Child, 21-0843

S.W. born Dec. 2019; mother reported alcohol and long-term methamphetamine, cocaine, and marijuana use. Newborn concerns included failure to thrive and suspected fetal alcohol spectrum disorder (FASD).
Child missed medical care: mother missed or rescheduled 18 medical visits in first 10 months; child required hospitalization and further diagnostic testing mother did not acknowledge.
Mother exhibited mental-health symptoms (visual hallucinations, paranoia) at some appointments and has a prior termination of parental rights for another child tied to long-term meth use.
After removal in Oct. 2020, S.W. tested positive for methamphetamine, marijuana, and cocaine; mother admitted post-birth meth use but refused consistent drug screens and substance-abuse treatment.
Juvenile court adjudicated S.W. CINA; permanency plan required substance-abuse evaluation, mental-health treatment, and random drug screens; mother made minimal, inconsistent progress and denied the FASD diagnosis.
Court modified goal to termination; trial court terminated mother’s parental rights under Iowa Code §232.116(1)(g) and (h), focusing on (1)(h)(4): child could not safely be returned now or within six months. Mother appealed.

Issue	Mother's Argument	State's Argument	Held
Whether §232.116(1)(h)(4) was proved: child could not be returned to mother now	Mother argues she showed reduced meth use and appropriate supervised visits; thus child could safely be returned	State argues mother refused treatment and drug screens, has chronic substance and mental-health issues, failed to address child’s medical needs including FASD	Court affirmed: clear and convincing evidence supports (1)(h)(4); mother not ready to resume custody
Whether court should grant a six-month extension of placement	Mother asks for six months to complete therapy and stabilize supports	State argues mother made almost no progress and nothing shows removal need would end in six months	Court denied extension: no record support that six months would eliminate removal need
Whether mother’s claim that DHS failed to make reasonable reunification efforts bars termination	Mother claims insufficient DHS efforts	State and court note parent must request additional services and did not; claim was waived	Court treated claim as waived per Iowa precedent

In re A.B., 957 N.W.2d 280 (Iowa 2021) (de novo review; State must prove grounds for termination by clear and convincing evidence)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (termination may be affirmed on any ground supported by record)
In re A.M., 843 N.W.2d 100 (Iowa 2014) (parent must be ready to resume custody by termination hearing)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (unresolved chronic drug addiction can render parent unfit)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (statutory urgency for termination after required period; special concern for children under three)
In re A.C., 415 N.W.2d 609 (Iowa 1987) (court should consider limited time children have to reach permanency when weighing extensions)
In re A.A.G., 708 N.W.2d 85 (Iowa Ct. App. 2005) (reasonable-efforts claim may be waived if parent fails to request additional services)