parents challenge in Iowa

2025See id. at 40 (stating we need not address steps the parents do not challenge on appeal).

2023Though the juvenile court terminated under both Iowa Code section 232.116(1)(d) and (h), the parents only challenge (h); but, “we may affirm the juvenile court’s termination order on any ground that we find supported by clear and convincing evidence.” In re D.W., 791 N.W.2d 703, 707 (Iowa 2010); see also In re P.L., 778 N.W.2d 33, 40 (Iowa 2010) (finding the court did “not have to discuss this step” where the parent did not dispute the existence of at least some of the statutory grounds); see, e.g., In re G.N., No. 20-1128, 2020 WL 7022388 , at *1 (Iowa Ct. App. Nov. 30, 2020) (collecting case

2024A. Ground for Termination In their mirroring claims, the parents challenge the State’s proof of the final element of section 232.116(1)(f), that the children could not be safely returned to parental custody at the time of the termination hearing.3 See Iowa Code § 232.116 (1)(f)(4) (requiring clear and convincing evidence that child cannot be returned to parental custody “at the present time”); In re D.W., 791 N.W.2d 703, 707 (Iowa 2010) (interpreting the statutory language “at the present time” to mean “at the time of the termination hearing”).

2023Though the juvenile court terminated under both Iowa Code section 232.116(1)(d) and (h), the parents only challenge (h); but, “we may affirm the juvenile court’s termination order on any ground that we find supported by clear and convincing evidence.” In re D.W., 791 N.W.2d 703, 707 (Iowa 2010); see also In re P.L., 778 N.W.2d 33, 40 (Iowa 2010) (finding the court did “not have to discuss this step” where the parent did not dispute the existence of at least some of the statutory grounds); see, e.g., In re G.N., No. 20-1128, 2020 WL 7022388 , at *1 (Iowa Ct. App. Nov. 30, 2020) (collecting case

2018See In re C.D., 508 N.W.2d 97, 101 (Iowa Ct. App. 1993).

2018See In re C.D., 508 N.W.2d 97, 101 (Iowa Ct. App. 1993).

2026The parents claim the State presented insufficient proof of the fourth element, which requires clear and convincing evidence that the child cannot be returned to parental custody at the present time as provided in section 232.102.3 Iowa Code § 232.116 (1)(h)(4); In re L.M., 904 N.W.2d 835, 839 (Iowa 2017) (finding “at the present time” means the date of the termination hearing).

2022However, neither parent raised this issue before the termination hearing. “[P]arents have a responsibility to object when they claim the nature or extent of services is inadequate.” In re L.M., 904 N.W.2d 835 , 839–40 (Iowa 2017).

2025“When the juvenile court terminates parental rights on more than one statutory ground,” we may affirm “on any ground we find supported by the record.” In re A.B., 815 N.W.2d 764, 774 (Iowa 2012).

2023However, we begin with each parent’s argument that the department failed to make reasonable efforts at reunifying them with the child, as a reasonable- efforts challenges implicates both section 232.116(1)(d) and (h) and the reasonable-efforts requirement “impacts the burden of proving those elements of termination which require reasonable efforts.” In re C.B., 611 N.W.2d 489, 492, 493 (Iowa 2000).

2022See In re S.R., 600 N.W.2d 63, 64 (Iowa Ct. App. 1999).

2020See In re C.H., 652 N.W.2d 144, 148 (Iowa 2002) (finding a parent could not challenge on appeal the services provided when the issue had not been presented to the juvenile court).

2017See In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). 3 ‘clear and convincing,’ it is merely necessary that there be no serious or substantial doubt about the correctness of the conclusion drawn from it.” Raim v. Stancel, 339 N.W.2d 621, 624 (Iowa Ct. App. 1983); see also M.W., 876 N.W.2d at 219 .

2017See In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). 3 ‘clear and convincing,’ it is merely necessary that there be no serious or substantial doubt about the correctness of the conclusion drawn from it.” Raim v. Stancel, 339 N.W.2d 621, 624 (Iowa Ct. App. 1983); see also M.W., 876 N.W.2d at 219 .

2017Our supreme court has recently addressed the issue of removal and held the purpose of removal is to ensure “that before termination occurs under these subsections, a parent has had a chance at physical custody in the past that has been unsuccessful.” In re C.F.- H., 889 N.W.2d 201, 207 (Iowa 2016), reh'g denied (Feb. 10, 2017).

2014Specifically, they assert the children’s placement in the homes of relatives and the closeness of their bond with the children should prevent termination. “‘The factors weighing against termination in section 232.116(3) are permissive, not mandatory,’ and the court may use its discretion, ‘based on the unique circumstances of each case and the best interests of the child, whether to apply the factors in this section to save the parent-child relationship.’” A.M., 843 N.W.2d at 113 (citation omitted).