67 Iowa opinions name it 2 courts 1955–2026 48 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.
| Case | Followed | Cited |
|---|---|---|
In Re P.L.green2 sentences2026See id. at 40 (recognizing we need not consider a step the parent does not challenge). 2024But when the parent does not raise a claim relating to any of the three steps, we do not address that step and instead limit our review to the specific claims presented. 7 See id. at 40 (recognizing we do not consider a step the parent does not challenge). | 55 | 56 |
In Re CHgreen2 sentences2024See In re C.H., 652 N.W.2d 144, 148 (Iowa 2002) (requiring a parent to challenge reasonable efforts “at the proper time” or risk “waiv[ing] the issue”); In re T.S., 868 N.W.2d 425, 442 (Iowa Ct. App. 2015) (“While the State has an obligation to provide reasonable services to preserve the family unit, it is the parent’s responsibility ‘to demand other, different, or additional services prior to the termination hearing.’” (citation omitted)). 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). | 2 | 2 |
In the Interest of L.M.W.green2 sentences2018See id. 2018See id. | 2 | 2 |
In the Interest of A.B. & S.B., Minor Children, S.B., Fathergreen1 sentence2025See In re E.V.-C., No. 24-1808, 2025 WL 401959 , at *2–3 (Iowa Ct. App. Feb. 5, 2025) (recognizing In re J.R., 20 N.W.3d 839, 842 (Iowa Ct. App. 2025) allows a parent to challenge the sufficiency of the evidence as to the statutory grounds for the first time on appeal but refusing to consider the unpreserved issue of a request for more time to work toward reunification); see also In re A.B., 815 N.W.2d 764, 773 (Iowa 2012) (“[T]he general rule that appellate arguments must first be raised in the trial court applies to [child-in-need-of- assistance] and termination of parental rights cases.”). | 1 | 1 |
In the Interest of T.S. and K.G., Minor Children, L.G., Mother, K.G., Father of K.G.green1 sentence2024See In re C.H., 652 N.W.2d 144, 148 (Iowa 2002) (requiring a parent to challenge reasonable efforts “at the proper time” or risk “waiv[ing] the issue”); In re T.S., 868 N.W.2d 425, 442 (Iowa Ct. App. 2015) (“While the State has an obligation to provide reasonable services to preserve the family unit, it is the parent’s responsibility ‘to demand other, different, or additional services prior to the termination hearing.’” (citation omitted)). | 1 | 1 |
In the Interest of C.K.green1 sentence2020See In re C.K., 558 N.W.2d 170, 174 (Iowa 1997) (“An appropriate determination to terminate a parent-child relationship is not to be countermanded by the ability and willingness of a family relative to take the child.”). | 1 | 1 |
In the Interest of J.D.B.green1 sentence2018See In J.D.B., 584 N.W.2d 577, 581 (Iowa Ct. App. 1998) (finding a parent could not challenge deficiencies in the CINA proceedings in a termination case when there had been no appeal of the CINA proceedings); In re A.W., 464 N.W.2d 475, 477 (Iowa Ct. App. 1990) (stating when the CINA dispositional order is entered, a CINA adjudication order becomes final for purposes of appeal). | 1 | 1 |
In the Interest of A.W.green1 sentence2018See In J.D.B., 584 N.W.2d 577, 581 (Iowa Ct. App. 1998) (finding a parent could not challenge deficiencies in the CINA proceedings in a termination case when there had been no appeal of the CINA proceedings); In re A.W., 464 N.W.2d 475, 477 (Iowa Ct. App. 1990) (stating when the CINA dispositional order is entered, a CINA adjudication order becomes final for purposes of appeal). | 1 | 1 |
In The Interest Of D.W., Minor Child, A.M.W., Mothergreen1 sentence2017In re D.W., 791 N.W.2d 703, 707 (Iowa 2010). | 1 | 1 |
Herr v. Lazorgreen2 sentences1955Joiner and Durst cases, supra, and citations; Herr v. Lazor, 238 Iowa 518, 526-528 , 28 N.W.2d 11, 15, 16 ; Paulson v. Windelow, supra, 236 Iowa 1011, 1016 , 20 N.W.2d 470, 473 . 1955Joiner and Durst cases, supra, and citations; Herr v. Lazor, 238 Iowa 518, 526-528 , 28 N.W.2d 11, 15, 16 ; Paulson v. Windelow, supra, 236 Iowa 1011, 1016 , 20 N.W.2d 470, 473 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In the Interest of M.W. and Z.W., Minor Children, R.W., Mother
green
2 sentences2025If we conclude termination of parental rights is in the best interests of a child, we then consider “whether any exceptions in section 232.116(3) apply to preclude termination.” Id. at 220 . 7 B.M. does not appeal the termination of his parental rights. 8 “However, if a parent does not challenge a step in our analysis, we need not address it.” In re J.P., No. 19-1633, 2020 WL 110425 , at *1 (Iowa Ct. App. Jan. 9, 2020). 2025Id. at 220 . 4 The father testified during the termination hearing that he recently started to address his substance-use issues. 5 The juvenile court also terminated the mother’s parental rights to L.H., but she does not appeal. 6 “However, if a parent does not challenge a step in our analysis, we need not address it.” In re J.P., No. 19-1633, 2020 WL 110425 , at *1 (Iowa Ct. App. Jan 9, 2020). | 2 | 2025–2025 |
Wheatley Ex Rel. Wheatley v. Heideman
green
2 sentences1974Cf. Wheatley v. Heideman, 251 Iowa 695 , 102 N.W.2d 343 (1960), and citations. 1974Cf. Wheatley v. Heideman, 251 Iowa 695 , 102 N.W.2d 343 (1960), and citations. | 1 | 1974–1974 |
Paulson Ex Rel. Paulson v. Windelow
green
2 sentences1955Joiner and Durst cases, supra, and citations; Herr v. Lazor, 238 Iowa 518, 526-528 , 28 N.W.2d 11, 15, 16 ; Paulson v. Windelow, supra, 236 Iowa 1011, 1016 , 20 N.W.2d 470, 473 . 1955Joiner and Durst cases, supra, and citations; Herr v. Lazor, 238 Iowa 518, 526-528 , 28 N.W.2d 11, 15, 16 ; Paulson v. Windelow, supra, 236 Iowa 1011, 1016 , 20 N.W.2d 470, 473 . | 1 | 1955–1955 |
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.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.