IN THE INTEREST OF C.K., Minor Child, A.K., Mother, Appellant.
No. 25-1323
IN THE COURT OF APPEALS OF IOWA
Filed October 29, 2025
A mother appeals the termination of her parental rights. AFFIRMED.
Robert W. Davison, Cedar Rapids, for appellant mother.
Brenna Bird, Attorney General, and Tamara Knight, Assistant Attorney General, for appellee State.
Michelle M. Jay of Bray & Klockau, P.L.C., Des Moines, Attorney and Guardian ad Litem for minor child.
Considered without oral argument by Schumacher, P.J., and Badding and Langholz, JJ.
A mother appeals the termination of her parental rights to her child under
I. Background Facts and Proceedings
“She‘s sunshine.” That‘s how the mother described her three-year-old daughter at the hearing to terminate her parental rights. The child was born prematurely in January 2022 due to a condition called cytomegalovirus. She was later diagnosed with other medical conditions, including cerebral palsy, microcephaly, diffuse cerebral and cerebellar atrophy, and periventricular leukomalacia. Because the child‘s umbilical cord tested positive for marijuana at birth, the Iowa Department of Human Services2 provided voluntary services to the family for about six months.
The department became involved again in June 2024 on a report that the mother was allowing a registered sex offender to care for the child and that there was domestic violence in the home. The State petitioned to have the child adjudicated in need of the court‘s assistance. The mother stipulated to the adjudication in August, and the child was allowed to remain in her custody under
In the months between the child‘s removal and the permanency hearing in April 2025, the mother made minimal progress towards reunification. While the mother‘s supervised visits with the child were positive, her attendance at those visits was inconsistent. She also failed to take advantage of the foster family‘s open invitation to their home for visits with the child. The mother attended only two of the child‘s sixty physical, occupational, and speech therapy sessions, and none of the twenty-five medical appointments for the child. She waited until January 2025 to complete a mental-health evaluation and did not complete a substance-use evaluation until April—just before the permanency hearing. Out of the thirty-four drug tests requested by the department, the mother only participated in four—all of which were positive for illegal substances.3
The mother entered inpatient substance-use treatment in mid-May, close to one month after the State petitioned to terminate her parental rights. She admitted that she used methamphetamine the day before she went into treatment. But by the termination hearing in July, she was forty-five days sober. She was also
The juvenile court denied the mother‘s request and terminated her parental rights under
by her own admission, she is not in a position to be a full-time parent at the present time. [The mother] believes she can be ready to parent [the child] in “a couple of months.” The Court is not convinced. [The mother] was very slow to engage in services. She has only been in treatment for a little over a month and her last use of methamphetamine was the day before she entered treatment. [The mother] is unemployed and does not have a home for [the child] to return to.
The mother appeals.
II. Analysis
In reviewing the juvenile court‘s ruling, we use a three-step analysis that asks whether (1) a statutory ground for termination is satisfied, (2) termination is in the best interests of the child, and (3) any of the permissive exceptions to termination should be applied. L.B., 970 N.W.2d at 313; see also
On the first step, the mother only challenges the final element of
After more than a decade of illegal substance use, the mother had been sober for just forty-five days at the time of the termination hearing. And that sobriety only occurred in a supervised setting. See In re P.F., No. 15-1103, 2015 WL 5970017, at *3 (Iowa Ct. App. Oct. 14, 2015) (recognizing that sobriety in a structured, custodial setting does not demonstrate an ability to maintain sobriety in the community). While the mother has done well in treatment, she has a long road ahead of her, which includes finding a home and a job. These struggles would be difficult for any parent to overcome. They are even harder for the parent of a
The mother combines the next two steps into one issue heading, which asserts the juvenile court “erred when it determined that termination would be in the child[]‘s best interests pursuant to Iowa Code [s]ection 232.116(2)-(3).” She focuses on her bond with the child, which is a relevant consideration in both steps. See In re L.A., 20 N.W.3d 529, 535 (Iowa Ct. App. 2025) (“A child‘s mental and emotional condition and needs is inherently impacted by the child‘s bond with a parent, so the parent-child bond is a relevant consideration in the best-interests analysis.“); see also
The social worker, guardian ad litem, and foster mother all agreed that the mother shared a close bond with the child. They each described how the child and mother would “light up when they see each other.” But the defining elements of a
We also find the mother failed to prove by clear and convincing evidence that “termination would be detrimental to the child at the time due to the closeness of the parent-child relationship.”
Lastly, the mother claims that she should “be given a few more months, under court supervision, to prove that she can care for the child and keep her safe.” She does not, however, provide us with any “specific factors, conditions, or expected behavioral changes which [would] comprise the basis for the determination that the need for removal . . . will no longer exist at the end of” the requested extension.
AFFIRMED.