1. At any time prior to expiration of a dispositional order and upon the motion of an
authorized party or upon its own motion as provided in this section, the court may terminate
the order and discharge the child, modify the order, or vacate the order and make a new order.
2. The following persons shall be authorized to file a motion to terminate, modify, or
vacate and substitute a dispositional order:
a. The child.
b. The child’s parent, guardian, or custodian, except that such motion may be filed by that\n\nTue Dec 09 22:21:33 2025 Iowa Code 2026, Chapter 232 (92, 1)
81 JUVENILE JUSTICE, §232.103A\n\nperson not more often than once every sixty days except with leave of court for good cause
shown.
c. The child’s guardian ad litem.
d. A person supervising the child pursuant to a dispositional order.
e. An agency, facility, institution, or person to whom legal custody has been transferred
pursuant to a dispositional order.
f. The county attorney.
3. A change in the level of care for a child who is subject to a dispositional order for
out-of-home placement requires modification of the dispositional order. A hearing shall
be held on a motion to terminate or modify a dispositional order except that a hearing on
a motion to terminate or modify an order may be waived upon agreement by all parties.
Reasonable notice of the hearing shall be given to the parties. The hearing shall be
conducted in accordance with the procedure established for dispositional hearings under
section 232.50, subsection 3.
4. The court may modify a dispositional order, vacate and substitute a dispositional order,
or terminate a dispositional order and release the child if the court finds that any of the
following circumstances exist:
a. The purposes of the order have been accomplished and the child is no longer in need
of supervision, care, or treatment.
b. The purposes of the order cannot reasonably be accomplished.
c. The efforts made to effect the purposes of the order have been unsuccessful and other
options to effect the purposes of the order are not available.
d. The purposes of the order have been sufficiently accomplished and the continuation of
supervision, care, or treatment is unjustified or unwarranted.
5. The court may modify or vacate an order for good cause shown provided that where
the request to modify or vacate is based on the child’s alleged failure to comply with the
conditions or terms of the order, the court may modify or vacate the order only if it finds
that there is clear and convincing evidence that the child violated a material and reasonable
condition or term of the order.
6. If the court vacates the order it may make any other order in accordance with and
subject to the provisions of sections 232.100 through 232.102.
[C79, 81, §232.103]
90 Acts, ch 1239, §12; 2001 Acts, ch 135, §20; 2003 Acts, ch 117, §6; 2004 Acts, ch 1154, §1,
2; 2012 Acts, ch 1021, §51; 2017 Acts, ch 54, §72; 2019 Acts, ch 100, §5; 2020 Acts, ch 1062,
§34; 2020 Acts, ch 1063, §90; 2022 Acts, ch 1098, §50
Referred to in §232.99, 232.102, 232.104
\n
Notes of Decisions
Cited in
92
cases (
29 in the last 5 years), 1981–2025 · leading case:
In the Interest of K.N., 625 N.W.2d 731 (Iowa 2001).
In Interest of RF, 471 N.W.2d 821 (Iowa 1991).
· cites it 12× “The issue remains whether section 232.103 permits it. R.F. argues that there is no statutory authority for ex parte removal of a child under either section 232.”
In the Interest of N.M., 528 N.W.2d 94 (Iowa 1995).
· cites it 6× “Marcy argues that the permanency hearing was not a valid proceeding under Iowa Code section 232.103 because the court im-permissibly initiated the hearing.”
In the Interest of J.F., 386 N.W.2d 149 (Iowa Ct. App. 1986).
· cites it 8× “102; (3) in exceeding its authority to modify a dispositional order under Iowa Code section 232.103; (4) in finding there was sufficient evidence to justify modification of the previous disposi-tional order and separation of the children; and (5) in not applying the proper…”
In the Interest of Blackledge, 304 N.W.2d 209 (Iowa 1981).
· cites it 4× “Modification of a dispositional order is provided for in section 232.103. Even when a court wishes on its own motion to modify the order, unless hearing is waived, the change may be made only after notice and hearing.”
Matter of Guardianship of Murphy, 397 N.W.2d 686 (Iowa 1986).
· cites it 4× “The full termination of a juvenile proceeding is provided by section 232.103(4) which provides: The court may terminate [a CHINA dispositional] order and release the child if the court finds that the purposes of the order have been accomplished and the child is no longer in need…”
In the Interest of Leehey, 317 N.W.2d 513 (Iowa Ct. App. 1982).
· cites it 4× “The guardian ad litem argues that the proceeding constituted a section 232.103 modification hearing, that notice was given to all interested parties, and that those parties appeared at the hearing.”
In the Interest of T.M.C., 429 N.W.2d 165 (Iowa Ct. App. 1988).
· cites it 6× “See Iowa Code § 232.103 (4). C.C. resisted the State’s motion and requested a modification of the dispositional order placing the children, on a trial basis, with a paternal aunt in Illinois.”
In the Interest of R.C., 523 N.W.2d 757 (Iowa Ct. App. 1994).
· cites it 4× “First, we do not agree the permanency order was made pursuant to section 232.103(2)(b). The order did not continue the children's placement.”
In the Interest of M.A.P., 679 N.W.2d 683 (Iowa Ct. App. 2004).
· cites it 6× “See Iowa Code § 232.103 (2)(b). Because a motion to vacate may be filed, “[a]t any time prior to expiration of a dispositional order .”
In the Interest of C.D., 509 N.W.2d 509 (Iowa Ct. App. 1993).
· cites it 2× “The mother contends the trial court erred in failing to modify visitation and service provisions of a permanency order.”
— Iowa Code § 232.103(1) — 4 cases
In Interest of RF, 471 N.W.2d 821 (Iowa 1991).
“The issue remains whether section 232.103 permits it. R.F. argues that there is no statutory authority for ex parte removal of a child under either section 232.”
In the Interest of M.A.P., 679 N.W.2d 683 (Iowa Ct. App. 2004).
“See Iowa Code § 232.103 (2)(b). Because a motion to vacate may be filed, “[a]t any time prior to expiration of a dispositional order .”
In Re Maf, 679 N.W.2d 683 (Iowa Ct. App. 2004).
— Iowa Code § 232.103(12)(b) — 1 case
— Iowa Code § 232.103(2) — 2 cases
— Iowa Code § 232.103(2)(b) — 5 cases
In the Interest of R.C., 523 N.W.2d 757 (Iowa Ct. App. 1994).
“First, we do not agree the permanency order was made pursuant to section 232.103(2)(b). The order did not continue the children's placement.”
In the Interest of Blackledge, 304 N.W.2d 209 (Iowa 1981).
“Modification of a dispositional order is provided for in section 232.103. Even when a court wishes on its own motion to modify the order, unless hearing is waived, the change may be made only after notice and hearing.”
— Iowa Code § 232.103(3) — 6 cases
In Interest of RF, 471 N.W.2d 821 (Iowa 1991).
“The issue remains whether section 232.103 permits it. R.F. argues that there is no statutory authority for ex parte removal of a child under either section 232.”
In the Interest of J.F., 386 N.W.2d 149 (Iowa Ct. App. 1986).
“102; (3) in exceeding its authority to modify a dispositional order under Iowa Code section 232.103; (4) in finding there was sufficient evidence to justify modification of the previous disposi-tional order and separation of the children; and (5) in not applying the proper…”
In the Interest of Blackledge, 304 N.W.2d 209 (Iowa 1981).
“Modification of a dispositional order is provided for in section 232.103. Even when a court wishes on its own motion to modify the order, unless hearing is waived, the change may be made only after notice and hearing.”
— Iowa Code § 232.103(4) — 34 cases
Matter of Guardianship of Murphy, 397 N.W.2d 686 (Iowa 1986).
“The full termination of a juvenile proceeding is provided by section 232.103(4) which provides: The court may terminate [a CHINA dispositional] order and release the child if the court finds that the purposes of the order have been accomplished and the child is no longer in need…”
In the Interest of T.M.C., 429 N.W.2d 165 (Iowa Ct. App. 1988).
“See Iowa Code § 232.103 (4). C.C. resisted the State’s motion and requested a modification of the dispositional order placing the children, on a trial basis, with a paternal aunt in Illinois.”
— Iowa Code § 232.103(4)(a) — 5 cases
— Iowa Code § 232.103(4)(b) — 3 cases
— Iowa Code § 232.103(4)(c) — 4 cases
— Iowa Code § 232.103(4)(d) — 1 case
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.