permanency or termination hearing in Iowa

2026See In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005) (“[HHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.”).

2024See In re W.J., No. 21-1991, 2022 WL 610559 , at *1 (Iowa Ct. App. Mar. 2, 2022) (finding a parent waived an issue by making only a “conclusory statement unaccompanied by factual arguments, legal arguments, legal citations, or references to the record”); In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005) (“The [d]epartment has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.

2020Furthermore, a “parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005); see also In re C.H., 652 N.W.2d 144, 148 (Iowa 2002) (citations omitted).

2020“The reasonable efforts concept would broadly include a visitation arrangement designed to facilitate reunification while protecting the child from the harm responsible for the removal.” In re M.B., 553 N.W.2d 343, 345 (Iowa Ct. App. 1996). “[W]hat constitutes reasonable services varies based upon the requirements of each individual case.” In re C.H., 652 N.W.2d 144, 147 (Iowa 2002). “[DHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In r

2018In re A.N., No. 02-1985, 2003 WL 291627 , at *3 (Iowa Ct. App. Feb. 12, 2003) (finding the juvenile court did not err in relieving DHS from providing further reunification services when services were not challenged before the hearing changing the permanency goal to termination); see In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005) (holding the DHS “has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing”); In re S.R., 600 N.W.2d 63, 65 (Iowa Ct. Ap

2017See In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005) (“The [IDHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.”); In re S.R., 600 N.W.2d 63, 65 (Iowa Ct. App. 1999) (noting the demand for services is necessary to preserve error).

2020“The reasonable efforts concept would broadly include a visitation arrangement designed to facilitate reunification while protecting the child from the harm responsible for the removal.” In re M.B., 553 N.W.2d 343, 345 (Iowa Ct. App. 1996). “[W]hat constitutes reasonable services varies based upon the requirements of each individual case.” In re C.H., 652 N.W.2d 144, 147 (Iowa 2002). “[DHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In r

2019“The concept of reasonable efforts broadly includes ‘a visitation agreement designed to facilitate reunification while protecting the child from the harm responsible for the removal.’” Id. (quoting In re M.B., 553 N.W.2d 343, 345 (Iowa Ct. App. 1996)). “[DHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005).

2019“The State must show reasonable efforts as a part of its ultimate proof the child cannot be safely returned to the care of a parent.” In re L.M., 904 N.W.2d 835, 839 (Iowa 2017). “[W]hat constitutes reasonable services varies based upon the requirements of each individual case.” In re C.H., 652 N.W.2d 144, 147 (Iowa 2002). “[DHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005).

2019“The State must show reasonable efforts as a part of its ultimate proof the child cannot be safely returned to the care of a parent.” In re L.M., 904 N.W.2d 835, 839 (Iowa 2017). “[W]hat constitutes reasonable services varies based upon the requirements of each individual case.” In re C.H., 652 N.W.2d 144, 147 (Iowa 2002). “[DHS] has an obligation to make reasonable efforts toward reunification, but a parent has an equal obligation to demand other, different, or additional services prior to a permanency or termination hearing.” In re A.A.G., 708 N.W.2d 85, 91 (Iowa Ct. App. 2005).

2005See In re S.R., 600 N.W.2d 63, 65 (Iowa Ct.App.1999); In re H.L.B.R., 567 N.W.2d 675, 679 (Iowa Ct.App.1997).

2005See In re S.R., 600 N.W.2d 63, 65 (Iowa Ct.App.1999); In re H.L.B.R., 567 N.W.2d 675, 679 (Iowa Ct.App.1997).

2023See In re S.P., 672 N.W.2d 842, 846 (Iowa 2003). 9 has a concomitant duty to demand more or different services before a permanency or termination hearing.

2023Id.

2019In her first constitutional claim, Geraldine asserts she received ineffective representation from her trial counsel for “not identifying issues or adequately addressing the lack of reasonable efforts.” “The test for ineffective assistance of counsel in termination cases is generally the same as in criminal proceedings.” In re A.R.S., 480 N.W.2d 888, 891 (Iowa 1992).