Iowa Code

Iowa Code § 232.113 (2026)

Right to and appointment of counsel

✓ current as of July 2026
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1. Upon the filing of a petition the parent identified in the petition shall have the right to counsel in connection with all subsequent hearings and proceedings. If the parent desires but is financially unable to employ counsel, the court shall appoint counsel. 2. Upon the filing of a petition the court shall appoint counsel for the child identified in the petition as a party to the proceedings. The same person may serve both as the child’s counsel and as guardian ad litem. [C79, 81, §232.113] Referred to in §232.108\n\n 232.114 Duties of county attorney. 1. As used in this section, “state” means the general interest held by the people in the health, safety, welfare, and protection of all children living in this state.

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Tue Dec 09 22:21:33 2025 Iowa Code 2026, Chapter 232 (92, 1) 89 JUVENILE JUSTICE, §232.116\n\n 2. Upon the filing of a petition the county attorney shall represent the state in all adversary proceedings arising under this subchapter and shall present evidence in support of the petition. 3. If there is disagreement between the department and the county attorney regarding the appropriate action to be taken, the department may request that the state be represented by the attorney general in place of the county attorney. If the state is represented by the attorney general, the county attorney may continue to appear in the proceeding and may present the position of the county attorney regarding the appropriate action to be taken in the case. 4. The county attorney and attorney general shall comply with the requirements of chapter 232B and the federal Indian Child Welfare Act, Pub. L. No. 95-608, when either chapter 232B or the federal Indian Child Welfare Act is determined to be applicable in any proceeding under this subchapter. [C81, §232.114] 89 Acts, ch 230, §18; 2013 Acts, ch 113, §3; 2017 Acts, ch 29, §53; 2020 Acts, ch 1062, §94

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Notes of Decisions
Cited in 26 cases (6 in the last 5 years), 1981–2024 · leading case: In the Interest of M.D., K.T., G.A., E.A. & S.A., Minor Child., 921 N.W.2d 229 (Iowa 2018).
In the Interest of M.D., K.T., G.A., E.A. & S.A., Minor Child., 921 N.W.2d 229 (Iowa 2018). · cites it 2× “§ 232.113 (providing the parent identified in a TPR petition with the right to counsel for all TPR hearings and proceedings); id.”
In the Interest of Dameron, 306 N.W.2d 743 (Iowa 1981). · cites it 2× “In concluding, we also note that the attorney who by appointment of the juvenile court has served throughout this proceeding as both the children’s counsel and their guardian ad litem pursuant to section 232.113, The Code 1979, has joined in and adopted the State’s brief and…”
State Pub. Def. v. Iowa Dist. Court for Linn Cnty., 728 N.W.2d 817 (Iowa 2007). · cites it 8× “See Iowa Code § 232.113 (1) (2003) (“[T]he parent identified in the petition shall have the right to counsel .”
J.E.B. v. K.C., 679 N.W.2d 645 (Iowa 2004). · cites it 4× “See Iowa Code § 232.113 (1) (“If the parent desires but is financially unable to employ counsel, the court shall appoint counsel.”
In the Interest of J.P.B., 419 N.W.2d 387 (Iowa 1988). · cites it 2× “In accordance with section 232.113, the juvenile judge appointed an attorney for the mother, an attorney for the children (Preacher), and a guardian ad litem for the children.”
Blakeney v. McRee, 188 So. 3d 1154 (Miss. 2016). “§ 31-32-2-5; Iowa Code Ann. § 232.113 (1); Kan. Stat. Ann.”
In the Interest of S.R., 548 N.W.2d 176 (Iowa Ct. App. 1996). · cites it 2× “Iowa Code § 232.113 (1995). Sherman was personally served with notice which stated, “If you are financially unable to hire an attorney, the Court will appoint one for you, if you notify the Clerk of Juvenile Court of this fact within five days after you receive this Notice.”
In the Interest of E.J.C., 731 N.W.2d 402 (Iowa Ct. App. 2007). · cites it 6× “In denying Rosa court appointed counsel, the district court reasoned that her request, coming on the eve of trial, was simply made too late for the hearing to proceed as scheduled. While late filed requests can certainly hinder the efficiency of a busy court docket, we find it…”
In the Interest of S.R., 554 N.W.2d 277 (Iowa Ct. App. 1996). · cites it 4× “The State then proceeds to argue that, unlike a party in a civil suit, a parent, whether incarcerated or not, is entitled to an attorney for a termination hearing pursuant to Iowa Code section 232.113 (1995). If the parent desired an attorney and could not afford one, a request…”
In Re Sajb, 679 N.W.2d 645 (Iowa 2004). · cites it 4× “See Iowa Code § 232.113 (1) ("If the parent desires but is financially unable to employ counsel, the court shall appoint counsel.”
In the Interest of R.S.N., 706 N.W.2d 705 (Iowa 2005). · cites it 2× “at 647-48, 650-51 (noting similarly situated parents in termination cases brought by the state under Iowa Code chapter 232 receive an attorney at public expense); Iowa Code § 232.113 (1) (stating on the filing of a termination petition the parent has the right to counsel, and…”
In the Interest of L.A.J., 495 N.W.2d 128 (Iowa Ct. App. 1992). · cites it 2× “Iowa Code §§ 232.113 , .126 (1991). The legislature, however, did not specify a parental right to counsel in delinquency proceedings under division two of chapter 232 which governs delinquency proceedings.”
— Iowa Code § 232.113(1) — 4 cases
In the Interest of E.J.C., 731 N.W.2d 402 (Iowa Ct. App. 2007). “In denying Rosa court appointed counsel, the district court reasoned that her request, coming on the eve of trial, was simply made too late for the hearing to proceed as scheduled. While late filed requests can certainly hinder the efficiency of a busy court docket, we find it…”
In Re Ejc, 731 N.W.2d 402 (Iowa Ct. App. 2007).
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.