L.T., Mother, Appellant. v. << (2026)

A mother appeals the termination of her parental rights to her then-two-year-old son.¹ Although it is questionable whether she properly challenges all three statutory grounds on which the juvenile court relied, assuming she did, we agree with the juvenile court that the State proved a ground under Iowa Code section 232.116(1)(h) (2026). And we agree that termination is in the son's best interest. We thus affirm the juvenile court's termination of the mother's parental rights.

I. Background Facts and Proceedings

This family first came to the attention of the Iowa Department of Health and Human Services (“HHS”) in late April 2025—when the son was one year old—over concerns of the father's illegal substance use and domestic violence. Around the same time, the mother contacted law-enforcement officers and told them that she was getting kicked out of her residence and could not provide her son with “basic needs such as food, diapers, and housing.” Initially, she requested that they take the son because she was “having a mental health breakdown,” was “overwhelmed,” and “wanted to give up the child before she did anything stupid.”

But when officers arrived at the motel to pick up the son, the mother changed her mind. She said she did not want HHS to take him, told the son that HHS was kidnapping him and they were going to hurt him, and began live-streaming the incident. So an ex parte removal order was requested and granted that same day. The mother again refused to cooperate with HHS when the order was executed later that day. She refused to provide HHS any placement options, the son's medical information, the son's belongings, her own contact information, or her future location.

The son was adjudicated in need of assistance about a month later. Since then, the mother has not been consistent in her services or visits. She finally met with HHS and a family-services provider at her residence in early June 2025. She reported that the residence was owned by a friend of hers who had just gone to jail for assaulting her. A few other friends lived there too. The mother shared that she would be homeless once the man was released from jail because she would have to leave when he returned to the house.

The first—and only—supervised visit between the mother and son since the removal happened in early July at a library. It did not go well. The mother became agitated early on, claiming that HHS had been abusing the son and that she needed to get him tested for sexually-transmitted diseases and engaging in inappropriate conversations with him about her allegations. She claimed the son's clothes he was wearing at the time were “dirty and covered in pee”—they were not—and took them off and threw them away and changed her son into clothes she had bought for him. She tried to take the son to the bathroom alone and yelled at the workers supervising the visit when they followed her. The mother began recording the incident and even called the police. After more arguing, the mother put the son in a stroller and started to leave the library. Eventually, police arrived and the mother calmed down.

A few days later, the son's guardian ad litem and attorney moved for a hearing “to determine if the actions of [the mother] pose a serious risk of physical or emotional harm to [the son] for future visits” because of her concerning behaviors at the visit. And after the hearing, the court suspended visitation and ordered the mother to “engage in a mental health evaluation and participate in any recommended treatment.” The court also indicated that it would reinstate visitation “upon a showing that [the mother's] mental health has improved and she can appropriately participate in interactions.”

But over the next few months the mother refused to take any drug tests and did not participate in services. She told HHS to stop contacting her. And in August, the mother was arrested on multiple assault charges.

Then in October, the mother reached out to HHS apologizing for her behavior, asking for forgiveness, and requesting help getting her son back. But still the mother failed to engage meaningfully in mental-health services and failed to complete drug tests when requested. She also repeatedly posted on social media describing her substance use and disparaging HHS and her court-appointed attorney. Indeed, her attorney moved to withdraw as counsel, citing her many social media posts criticizing him.

The mother completed a few drug tests in the following months. In February 2026, she tested positive for cocaine. And she tested positive for cocaine three separate times in April. She was also kicked out of the homeless shelter she had been staying at in April because of her “inappropriate behavior.”

In early May 2026, the juvenile court held a termination hearing. The State and the child's attorney and guardian ad litem urged the court to terminate the mother's parental rights. And the court ultimately agreed, terminating the mother's parental rights under paragraphs “b,” “e,” and “h” of Iowa Code section 232.116(1) after finding that termination was in the son's best interest because of “the mother's instability, substance abuse and mental health issues.” The mother now appeals.

II. Statutory Grounds for Termination

Terminating parental rights under Iowa Code chapter 232 follows a three-step process. In re L.B., 970 N.W.2d 311, 313 (Iowa 2022). First, the State must prove a statutory ground for termination. Id. Second, the State must show termination is in the best interest of the child. Id. And third, the parent has the burden to show whether a discretionary exception applies that should preclude termination. Id.; see also In re A.S., 906 N.W.2d 467, 476 (Iowa 2018). We need not address any steps not challenged by a parent. See In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). And we review a termination decision de novo, giving “respectful consideration” to the juvenile court's factual findings, especially when based on credibility determinations. In re W.M., 957 N.W.2d 305, 312 (Iowa 2021).

The juvenile court terminated the mother's parental rights under paragraphs “b,” “e,” and “h” of Iowa Code section 232.116(1). “When the juvenile court terminates parental rights on more than one statutory ground, we may affirm the juvenile court's order on any ground we find supported by the record.” In re A.B., 815 N.W.2d 764, 774 (Iowa 2012). And a parent must challenge every statutory ground on appeal to avoid our affirmance on an unchallenged ground. See, e.g., In re J.M., No. 25-2007, 2026 WL 685837, at *1 (Iowa Ct. App. Mar. 11, 2026). Because the mother only listed a challenge to the court's termination based on paragraph “b” as one of her issues for review and focused most of her argument on that ground—before a few brief mentions of the other two grounds—the mother may have waived her challenges to paragraphs “e” and “h,” letting us affirm on those grounds without further analysis. But even assuming that the issue is properly before us, we agree with the juvenile court that the State proved that termination is appropriate under paragraph “h.”

The mother seems not to dispute the first three elements of this ground for termination: the son's age under three years, his adjudication in need of assistance, and that he had been removed from her care for at least six of the last twelve months. Iowa Code § 232.116(1)(h)(1)–(3). Her only arguable challenge is on the fourth and final element—whether the son could not be returned to her custody at the time of the termination hearing.

On our de novo review, we agree with the juvenile court that he could not be returned. First, at the time of the termination hearing in early May 2026, it had been almost a year since the son had seen his mother. At that point, the mother was pregnant and homeless in Chicago—living at a hotel after being asked to leave a shelter. She attended the hearing virtually because she had a pregnancy-related medical appointment that same day and “didn't feel safe” trying to make it to court. She lacked stable employment. The mother did not meaningfully engage in the many services offered to her to correct her substance-use and mental-health issues. And she tested positive for cocaine multiple times less than a month before the termination hearing. We find that the State proved a ground for termination under paragraph “h” of Iowa Code section 232.116(1).

III. The Son's Best Interest

The mother also argues that termination is not in the best interest of the son mainly because of “the closeness of the parent-child relationship.”² Our “paramount concern in a termination proceeding” is the child's best interest. L.B., 970 N.W.2d at 313. We consider both the child's long-range and immediate best interests. See In re C.K., 558 N.W.2d 170, 172 (Iowa 1997). And we must “give primary consideration to the child's safety, to the best placement for furthering the long-term nurturing and growth of the child, and to the physical, mental, and emotional condition and needs of the child.” Iowa Code § 232.116(2); see In re M.W., 876 N.W.2d 212, 224 (Iowa 2016).

The child's safety counsels in favor of terminating the mother's parental rights for the same reasons that the son could not be returned to his mother's custody. What's more, the son was doing “phenomenal” with his foster family—who hoped to adopt him. We thus agree with the juvenile court that termination of the mother's parental rights is in the son's best interest. See In re A.M., 843 N.W.2d 100, 112–13 (Iowa 2014) (“[W]e cannot deprive a child of permanency after the State has proved a ground for termination under section 232.116(1) by hoping someday a parent will learn to be a parent and be able to provide a stable home for the child.” (cleaned up)).

AFFIRMED.

FOOTNOTES

1.   The father's rights were also terminated but he does not appeal. We avoid using the parties’ names to respect their privacy because this opinion—unlike the juvenile court's orders—is public. Compare Iowa Code § 232.147(2) (2026), with id. §§ 602.4301(2), 602.5110; see also Iowa Ct. R. 21.25.

2.   As part of the same numbered legal issue in her petition on appeal, the mother refers to the permissive parent-child-bond exception to termination. See Iowa Code § 232.116(3)(c). To the extent that the mother is trying to assert this as another claim on appeal, it is not preserved for our review because she did not raise the permissive exception before the juvenile court or obtain a ruling on it. See In re J.R., 20 N.W.3d 839, 843 (Iowa Ct. App. 2025) (en banc).

Opinion by Langholz, J.