section 232.116(1) least one statutory ground (Iowa) · Go Syfert
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section 232.116(1) least one statutory ground in Iowa

35 Iowa opinions name it 2 courts 2014–2026 16 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
In The Interest Of D.W., Minor Child, A.M.W., Mothergreen
iowa · 2010 · cited in 9 Iowa opinions naming this issue, 2014–2026
2 sentences

2026In re D.W., 791 N.W.2d 703, 706 (Iowa 2010).

2019In re D.W., 791 N.W.2d 703 , 706–07 (Iowa 2010). • First we must decide whether the evidence satisfies the ground alleged under section 232.116(1).

79
In Re P.L.green
iowa · 2010 · cited in 7 Iowa opinions naming this issue, 2014–2025
2 sentences

2025See In re P.L., 778 N.W.2d 33, 40 (Iowa 2010) (When a parent does not dispute the existence of grounds under section 232.116, “we do not have to discuss this step”).

2022In re P.L., 778 N.W.2d 33, 39 (Iowa 2010).

27
In the Interest of A.B. & S.B., Minor Children, S.B., Fathergreen
iowa · 2012 · cited in 2 Iowa opinions naming this issue, 2021–2023
2 sentences

2023See In re A.B., 815 N.W.2d 764, 774 (Iowa 2012) (“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.”).

2021See In re A.B., 815 N.W.2d 764, 774 (Iowa 2012) (“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.”).

22
W.M. and W.D.green
iowa · 2021 · cited in 2 Iowa opinions naming this issue, 2021–2021
2 sentences

2021See In re W.M., 957 N.W.2d 305 , 313 (Iowa 2021) (upholding termination on similar grounds under section 232.116(1)(f)).

2021See In re W.M., 957 N.W.2d 305 , 312 (Iowa 2021) (noting that after “the State has proven a ground for termination, the parent resisting termination bears the burden” of proving a ground under section 232.116(3) (quoting A.S., 906 N.W.2d at 476)).

22
In Re CBgreen
iowa · 2000 · cited in 2 Iowa opinions naming this issue, 2016–2017
2 sentences

2017Because the father did not challenge any of the statutory grounds under which his rights were terminated, he has waived the district court’s findings as to the 4 statutory grounds under Iowa Code section 232.116(1).1 See In re C.B. 611 N.W.2d 489, 492 (Iowa 2000) (“A broad, all-encompassing argument is insufficient to identify error in cases of de novo review.” (citing Hyler v. Garner, 548 N.W.2d 864, 870 (Iowa 1996))).

2016See Hyler v. Garner, 548 N.W.2d 864, 870 (Iowa 1996) (“[O]ur review is confined to those propositions relied upon by the appellant for reversal on appeal.”); see also C.B., 611 N.W.2d at 492 (“We have long recognized an appellant must identify alleged error on appeal.”).

22
In the Interest of J.B.L., Minor Child, Q.S., Fathergreen
iowactapp · 2014 · cited in 2 Iowa opinions naming this issue, 2016–2017
2 sentences

2017AFFIRMED. 1 We will not address whether grounds exist under section 232.116(1)(l) because “we need only find termination appropriate under one of [the] sections to affirm.” In re J.B.L., 844 N.W.2d 703, 704 (Iowa Ct. App. 2014).

2016See In re J.B.L., 844 N.W.2d 703, 704 (Iowa Ct. App. 2014). 8 C.

22
Hyler v. Garnergreen
iowa · 1996 · cited in 2 Iowa opinions naming this issue, 2016–2017
2 sentences

2017Because the father did not challenge any of the statutory grounds under which his rights were terminated, he has waived the district court’s findings as to the 4 statutory grounds under Iowa Code section 232.116(1).1 See In re C.B. 611 N.W.2d 489, 492 (Iowa 2000) (“A broad, all-encompassing argument is insufficient to identify error in cases of de novo review.” (citing Hyler v. Garner, 548 N.W.2d 864, 870 (Iowa 1996))).

2016See Hyler v. Garner, 548 N.W.2d 864, 870 (Iowa 1996) (“[O]ur review is confined to those propositions relied upon by the appellant for reversal on appeal.”); see also C.B., 611 N.W.2d at 492 (“We have long recognized an appellant must identify alleged error on appeal.”).

22
In the Interest of A.M., Minor Child, A.M., Fathergreen
iowa · 2014 · cited in 2 Iowa opinions naming this issue, 2022–2023
2 sentences

2023The grounds found in section 232.116(3) “are permissive, not mandatory.” In re A.M., 843 N.W.2d 100, 113 (Iowa 2014) (citation omitted).

2022The grounds in section 232.116(3) “are permissive, not mandatory.” A.M., 843 N.W.2d at 113 (quoting In re D.S., 806 N.W.2d 458, 474 (Iowa Ct. App. 2011)).

12
In The Interest Of P.l., Minor Child, O.l.-v., Fathergreen
iowa · 2010 · cited in 2 Iowa opinions naming this issue, 2022–2022
2 sentences

2022At the termination trial, the mother conceded the children could not be placed with her then. 4 The mother argues termination of her parental rights is not in the children’s best interests because she “love[s] both of her children tremendously.” In determining what is in the best interests of the children, we are “required to use the best-interest framework established in section 232.116(2).” In re P.L., 778 N.W.2d 33, 37 (Iowa 2010).

2022In re P.L., 2 The putative father does not appeal. 6 778 N.W.2d 33 , 39-40 (Iowa 2010).

12
In the Interest of L.M.green
iowa · 2017 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024She maintains that K.R. could be returned to her custody at the time of the termination hearing.6 See Iowa Code § 232.116 (1)(h)(4) (requiring clear and convincing proof “that the child cannot be returned to the custody of the child’s parents as provided in section 232.102”); see also In re L.M., 904 N.W.2d 835, 839 (Iowa 2017) (holding “at the present time” means the date of the termination hearing).

11
In the Interest of D.S.green
iowactapp · 2011 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022The grounds in section 232.116(3) “are permissive, not mandatory.” A.M., 843 N.W.2d at 113 (quoting In re D.S., 806 N.W.2d 458, 474 (Iowa Ct. App. 2011)).

11
State v. Manngreen
iowa · 1999 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019See State v. Mann, 602 N.W.2d 785 , 788 n.1 (Iowa 1999) (noting the mention of an issue without analysis, argument, or supporting authority is insufficient to prompt appellate consideration).4 The record indicates C.O. is younger than three years, was adjudicated as a child in need of assistance, has not been in the mother’s care for any of C.O.’s life, and the mother was incarcerated at the time of the termination hearing with a tentative release date in 2024.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
In Re RK green
iowactapp · 2002
2 sentences

2014Although “[w]e only need to find grounds to terminate parental rights under one of the sections cited by the district court in order to affirm its ruling,” see In re R.K., 649 N.W.2d 18 , 19 (Iowa Ct. App. 2000), we elect to address the father’s contention that statutory grounds under section 232.116(1)(h) have not been proved by clear and convincing evidence. 6 offered to the parents and, in fact, the child was able to return to their care for a brief time.

2014“We only need to find grounds to terminate parental rights under one of the sections cited by the district court in order to affirm its ruling,” see In re R.K., 649 N.W.2d 18 , 19 (Iowa Ct. App. 2000), and we elect to address the mother’s contention that statutory grounds under section 232.116(1)(d) have not been proved by clear and convincing evidence.7 Under that section, termination may be ordered when a child has been adjudicated in need of assistance for physical or sexual abuse or neglect and the circumstances continue despite receipt of services.

32014–2014
In the Interest of A.R. and A.R., Minor Children green
iowactapp · 2019
1 sentence

2024Id.

12024–2024
Meier v. SENECAUT III green
iowa · 2002
1 sentence

2021Id.

12021–2021

Statutes the citing opinions construe

IA § Iowa Code § 232.116 (35) IA § Iowa Code § 232.104 (20) IA § Iowa Code § 232.102 (16) IA § Iowa Code § 232.96 (12) IA § Iowa Code § 232.2 (4) IA § Iowa Code § 232.117 (3) IA § Iowa Code § 232B.3 (3) IA § Iowa Code § 232B.5 (3) USC § 25u.s.c.1912 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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