In the Interest of T.J.R., Minor Child, S.R., Mother, 16-1360

Child born April 2014; DHS involvement began December 2014 after the child was left alone while mother worked and father C.B. used illegal substances. Child adjudicated CINA and removed from mother’s care in August 2015.
Early concerns: parental substance and alcohol abuse, domestic violence between mother and C.B.; child abuse assessment founded for denial of critical care (father as perpetrator).
Mother initially failed to engage with services; after removal she attended substance‑abuse and mental‑health treatment, maintained housing and employment, and participated in supervised/semisupervised visitation.
Significant safety concerns persisted: mother disputed need for corrective eye surgery for child (congenital ptosis) and cancelled/failed to follow through with medical appointments; DHS required court order to proceed with surgery.
Mother repeatedly failed to provide adequate, safe nutrition for a child who has swallowing difficulties (examples include feeding mostly Pringles or minimal yogurt), and performed poorly during an overnight visit (late return, sparsely fed, untreated illness).
Mother remained ambivalent and financially/emotionally dependent on C.B., with inconsistent willingness to end that violent relationship; at termination hearing C.B. was incarcerated. Foster family seeks to adopt and provided needed medical and nutritional care.

Issue	Mother (Plaintiff) Argument	State/DHS (Defendant) Argument	Held
Whether grounds for termination under Iowa Code §232.116(1)(h) are proved	Mother argued State failed to prove statutory grounds (disputed medical necessity and care allegations)	State argued child <3, adjudicated CINA, out of mother’s custody >6 months, and cannot be safely returned due to medical, nutritional, and domestic‑violence risks	Court held clear and convincing evidence supports termination under §232.116(1)(h)
Whether termination is in child’s best interests	Mother contended termination would harm child and disrupt a parent‑child bond	State emphasized child’s safety, medical and nutritional needs, and stable foster placement supporting long‑term growth	Court held termination is in child’s best interests
Whether the parent‑child bond exception (§232.116(3)(c)) precludes termination	Mother argued a strong bond exists and termination would be detrimental	State argued bond does not outweigh safety risks and inability to provide necessary care	Court held the parent‑child bond did not outweigh the need for termination
Whether additional six‑month continuance for reunification under §232.104(2)(b) should be granted	Mother requested six more months to improve and seek reunification	State argued mother’s past performance shows little likelihood of remedy in six months	Court denied six‑month extension as unlikely to change conditions

In re J.E., 723 N.W.2d 793 (Iowa 2006) (standard of review for termination appeals)
In re D.W., 791 N.W.2d 703 (Iowa 2010) (weight given to juvenile court fact findings and credibility)
In re A.B., 815 N.W.2d 764 (Iowa 2012) (affirmance may rest on any supported statutory ground)
In re C.B., 611 N.W.2d 489 (Iowa 2000) (parent’s past performance indicative of future care; child’s long‑range best interests)
In re D.S., 806 N.W.2d 458 (Iowa Ct. App. 2011) (paramount concern in termination is child’s best interests)