In the Interest of L.M., Minor Child, C.H., Mother, Appellant. v. << (2026)

A mother appeals the district court's adjudicatory and dispositional orders in a child-in-need-of-assistance (CINA) proceeding, “disput[ing] the court's determination that she committed child abuse on her child.” Upon our review, we affirm.

I. Background Facts and Proceedings

In November 2025, the mother brought her nine-year-old daughter, L.M., to the emergency department due to the child's “out-of-control behaviors.” When the mother left the room, L.M. told hospital personnel that her mother hit her “about six times” before they came to the hospital. The child had bruising on her thighs, including a “handprint” bruise on one leg. L.M. stated she did not feel safe with the mother because she “beats her” all the time.

The mother was erratic and distraught. She admitted she spanked L.M., but she equivocated about whether she had caused bruising. She acknowledged a “clear handprint” on L.M.’s leg, but she denied causing it. L.M. asked to go with her father. Initially the mother refused, but then she stated she would pack the child's bags “right now and they could keep her at the hospital.”

The emergency room provider took protective custody of the child. The mother was asked to leave the hospital, and L.M. was released the following day to the father, who exercised shared care of the child. L.M. completed a forensic interview and physical examination, which produced reports consistent with the child's description of the mother's abuse. L.M.’s younger half-brother was also interviewed. He reported that he also feared the mother and that the mother spanked he and L.M. a “billion” times. Meanwhile, the mother referred to L.M. as a “master manipulator” and maintained she wanted to “prove” she was not a child abuser.

The court filed an ex parte removal order in December, and the State filed a CINA petition. Following a hearing, the court adjudicated L.M. a CINA pursuant to Iowa Code section 232.96A(2), (3)(b), (12), and (14) (2025). The court did not find the mother's explanation of the events leading up to L.M.’s emergency room visit to be credible. The court further detailed evidence in the record of the mother's pattern of physical violence, irrational comments, emotional instability, and overall “disturbing pattern of behavior.”

In April, the court entered a disposition order continuing L.M.’s placement outside the mother's custody. Prior to the disposition hearing, the mother frequently canceled visits with the child or ended them early. She refused to allow visits to take place at her home because she did not want the father to know where she lived. The mother reported she was going to Florida to complete inpatient mental-health treatment. Meanwhile, the child felt safe and settled in her father's home. She was still attending the same school, where she was doing well.

The mother appeals the adjudication and disposition orders.

II. Standard of Review

We review the district court's decisions in CINA proceedings de novo. In re L.H., 904 N.W.2d 145, 149 (Iowa 2017). We are not bound by the court's factual findings, but we give weight to those findings. In re J.S., 846 N.W.2d 36, 40 (Iowa 2014). The court's “determinations must be based upon clear and convincing evidence.” Id. at 41. The child's best interests are our primary concern. Id. at 40.

III. Discussion

On appeal, the mother challenges the court's finding “that she committed child abuse on her child.” She maintains the court's conclusions “appear[ ] to be based more on the court's perception of the mother's demeanor during the hearing and some sketchy circumstantial evidence than evidence that would support a finding that the child met the criteria for a child in need of assistance.”

The mother's petition on appeal does not cite to any legal authority—statutory or otherwise—to support her claim. Indeed, the mother cites no authority in support of this issue. “Our appellate rules require each division of an argument state the issue presented and the authorities relied upon.” In re A.M.H., 516 N.W.2d 867, 873 (Iowa 1994). Because the mother's argument is not accompanied by any authorities or additional justification refuting the district court's determination, it is waived. Iowa R. App. P. 6.903(2)(a)(8)(3).

Even assuming the mother's challenge was properly before us, we would interpret it as a challenge solely to the CINA adjudication under section 232.96A(2).¹ Under that section, the adjudication requires a determination that a “parent, guardian, other custodian, or other member of the household in which the child resides has physically abused or neglected the child, or is imminently likely to physically abuse or neglect the child.” Iowa Code § 232.96A(2). Upon our de novo review, we concur with the district court that the record contains clear and convincing evidence that L.M. suffered a nonaccidental physical injury as the result of the mother's acts. See id. §§ 232.2(51) (defining physical abuse), 232.96A(2). We affirm the CINA adjudication under Iowa Code section 232.96A(2), (3)(b), (12), and (14).

We affirm the orders entered by the court.

AFFIRMED.

FOOTNOTES

1.   We further observe that although the mother mentions the disposition order in her petition on appeal, she makes no specific claim relating to it. We therefore conclude any challenge to the disposition order is waived. See Iowa R. App. P. 6.903(2)(a)(8)(3).

SCHUMACHER, Judge.