statutory best interest framework in Iowa

2026“Third, if the statutory best-interest framework supports termination of parental rights, the court must consider if any statutory exceptions set out in section 232.116(3) should serve to preclude termination of parental rights.” Id. at 707 .

2022Finally, “if the statutory best-interest framework supports termination of parental rights, [we] must consider if any statutory exceptions set out in section 232.116(3) should serve to preclude termination of parental rights.” Id.

2025We also draw from the statutory best-interest framework outlined in Iowa Code chapter 232, which directs the court to “give primary consideration to the child’s safety, to the best placement for furthering the long-term nurturing and 6 The mother testified that the paternal grandmother had some limited contact with the mother to set up contact for herself, rather than the father. 8 growth of the child, and to the physical, mental, and emotional condition and needs of the child.” Id. § 232.116(2); see In re A.H.B., 791 N.W.2d 687 , 690–91 (Iowa 2010) (finding it useful to apply the best-interes

2025We also draw from the statutory best-interest framework outlined in Iowa Code chapter 232, which directs the court to “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.” Id. § 232.116(2); see In re A.H.B., 791 N.W.2d 687 , 690–91 (Iowa 2010) (finding it useful to apply the best-interest framework of section 232.116(2) and (3) to the best-interest analysis under chapter 600A).

2022In re P.L., 778 N.W.2d 33, 37 (Iowa 2010).

2021Id.

2026Finally, if “the statutory best-interest framework supports termination of parental rights, we consider whether any exceptions in section 232.116(3) apply to preclude termination of parental rights.” Id. at 220 .

2023First, we “determine whether any ground for termination under section 232.116(1) has been established.” If we determine “that a ground for termination has been established, then we determine whether the best-interest framework as laid out in section 232.116(2) supports the termination of parental rights.” Finally, if we conclude the statutory best-interest framework supports termination, “we consider whether any exceptions in section 232.116(3) apply to preclude termination of parental rights.” In re A.S., 906 N.W.2d 467 , 472–73 (Iowa 2018) (quoting In re M.W., 876 N.W.2d 212 , 219–20 (Iowa 2

2022“When the juvenile court orders termination of parental rights on more than one statutory ground, we need only find grounds to terminate on one of the sections to affirm.” In re T.S., 868 N.W.2d 425, 435 (Iowa Ct. App. 2015). 6 A. Grounds for termination. 1.

2015Finally, if the court finds “the statutory best-interest framework supports termination of parental rights,” the court must consider “if any statutory exceptions set out in section 232.116(3) should serve to preclude termination of parental rights.” Id. at 707 . “[T]ermination is an outcome of last resort.” In re B.F., 526 N.W.2d 352, 356 (Iowa Ct. App. 1994).

2014Heather first contends none of the grounds for termination are supported by clear and convincing evidence. “[W]e need only find grounds to terminate under one of the sections cited by the juvenile court to affirm.” In re S.R., 600 N.W.2d 63, 64 (Iowa Ct. App. 1999).