Iowa Code

Iowa Code § 232.41 (2026)

Reporter required

✓ current as of July 2026

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Stenographic notes or mechanical or electronic recordings shall be taken of all court hearings held pursuant to this subchapter unless waived by the parties. The child shall not be competent to waive the reporting requirement, but waiver may be made for the child by the child’s counsel or guardian ad litem. Matters which must be reported under the provisions of this section shall be reported in the same manner as required in section 624.9. [C66, 71, 73, 75, 77, §232.32; C79, 81, §232.41] 2020 Acts, ch 1062, §94

Notes of Decisions

Cited in 26 cases, 1967–2016 · leading case: Alsager v. Dist. Court of Polk Cty., Iowa, 406 F. Supp. 10 (S.D. Iowa 1975).

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Alsager v. Dist. Court of Polk Cty., Iowa, 406 F. Supp. 10 (S.D. Iowa 1975). · cites it 23× “The parental termination statute of the Code of Iowa, § 232.41, provides: The court may upon petition terminate the relationship between parent and child: ****** 2.”

Long v. Long, 255 N.W.2d 140 (Iowa 1977). · cites it 10× “41(2)(e) which provided for termination of a parent-child relationship if the court finds: “That following an adjudication of neglect or dependency, reasonable efforts under the direction of the court have failed to correct the conditions leading to the termination.”

In the Interest of Lewis, 257 N.W.2d 505 (Iowa 1977). · cites it 13× “Despite the fact § 232.41 is not a crime-related enactment, the termination of parental rights is of such a grave nature that contemporary standards attendant upon the evaluation of vagueness in so-called criminal legislation are deemed applicable.”

In the Interest of Ponx, 276 N.W.2d 425 (Iowa 1979). · cites it 10× “8 proscribed at the time it occurred, or was it first declared to be a basis for termination by the new statute? Section 232.41 of the 1975 Code, which was the forerunner to section 600A.”

In the Interest of Crooks, 262 N.W.2d 786 (Iowa 1978). · cites it 17× “The appellant contends § 232.41(2)(e), The Code, 1975, which has since been repealed, was unconstitutionally vague on its face and as applied to the facts in this case, and also contends the grounds for termination stated in that statute were not established.”

State v. McDonald, 201 N.W.2d 447 (Iowa 1972). · cites it 11× “A Scott County juvenile probation officer had filed a petition seeking termination of the relationship in which it was alleged the relationship should be terminated in that the parents are unfit by reasons of conduct found by the court likely to be detrimental to the physical or…”

In the Interest of Hochmuth, 251 N.W.2d 484 (Iowa 1977). · cites it 6× “) provides the juvenile court shall base its findings and order on the termination of parental rights on clear and convincing proof.”

In the Interest of Wardle, 207 N.W.2d 554 (Iowa 1973). · cites it 8× “" These actions to terminate the parent-child relationship were instituted pursuant to section 232.41, The Code, which provides in part as follows: "When relationship changed.”

In the Interest of A.R., D.R., J.C. & J.C. Minor Child., A.M., Mother, 865 N.W.2d 619 (Iowa Ct. App. 2015). · cites it 4× “2d at 491 (finding it “unnecessary to decide whether the second ground alleged in the petition properly stated a basis for termination under section 232.41(2)(d), which, although not relied on by the trial court, would have justified termination”).”

Charles Leroy Alsager, Sr. & Darlene Lauvern Alsager v. Dist. Court of Polk Cnty., Iowa (Juv. Div.), 518 F.2d 1160 (8th Cir. 1975). · cites it 3× “Specifically under attack for vagueness is Iowa Code Ann. § 232.41 (1973) which provides that under certain conditions the state court may terminate the parent-child relationship.”

In the Interest of Robbins, 230 N.W.2d 489 (Iowa 1975). · cites it 5× “§ 232.41(2)(b), The Code. The other ground was an apparent attempt to paraphrase § 232.”

In the Interest of Kester, 228 N.W.2d 107 (Iowa 1975). · cites it 2× “These grounds were based on § 232.41(2)(a), (b), and (d), The Code. Those provisions are: “The court may upon petition terminate the relationship between parent and child: * ⅜ * * ⅜ # 2.”

Show all 26 citing cases →

— Iowa Code § 232.41(2) — 4 cases

State v. McDonald, 201 N.W.2d 447 (Iowa 1972). “A Scott County juvenile probation officer had filed a petition seeking termination of the relationship in which it was alleged the relationship should be terminated in that the parents are unfit by reasons of conduct found by the court likely to be detrimental to the physical or…”

In the Interest of Ponx, 276 N.W.2d 425 (Iowa 1979). “8 proscribed at the time it occurred, or was it first declared to be a basis for termination by the new statute? Section 232.41 of the 1975 Code, which was the forerunner to section 600A.”

In the Interest of Hochmuth, 251 N.W.2d 484 (Iowa 1977). “) provides the juvenile court shall base its findings and order on the termination of parental rights on clear and convincing proof.”

McCalester Ex Rel. Tatum v. Hillcrest Servs. to Child. & Youth, 232 N.W.2d 1 (Iowa 1975).

— Iowa Code § 232.41(2)(a) — 1 case

In the Interest of Kester, 228 N.W.2d 107 (Iowa 1975). “These grounds were based on § 232.41(2)(a), (b), and (d), The Code. Those provisions are: “The court may upon petition terminate the relationship between parent and child: * ⅜ * * ⅜ # 2.”

— Iowa Code § 232.41(2)(b) — 7 cases

Alsager v. Dist. Court of Polk Cty., Iowa, 406 F. Supp. 10 (S.D. Iowa 1975). “The parental termination statute of the Code of Iowa, § 232.41, provides: The court may upon petition terminate the relationship between parent and child: ****** 2.”

In the Interest of Hochmuth, 251 N.W.2d 484 (Iowa 1977). “) provides the juvenile court shall base its findings and order on the termination of parental rights on clear and convincing proof.”

Long v. Long, 255 N.W.2d 140 (Iowa 1977). “41(2)(e) which provided for termination of a parent-child relationship if the court finds: “That following an adjudication of neglect or dependency, reasonable efforts under the direction of the court have failed to correct the conditions leading to the termination.”

In the Interest of Lewis, 257 N.W.2d 505 (Iowa 1977). “Despite the fact § 232.41 is not a crime-related enactment, the termination of parental rights is of such a grave nature that contemporary standards attendant upon the evaluation of vagueness in so-called criminal legislation are deemed applicable.”

— Iowa Code § 232.41(2)(b)(d)(e) — 1 case

— Iowa Code § 232.41(2)(d) — 3 cases

In the Interest of A.R., D.R., J.C. & J.C. Minor Child., A.M., Mother, 865 N.W.2d 619 (Iowa Ct. App. 2015). “2d at 491 (finding it “unnecessary to decide whether the second ground alleged in the petition properly stated a basis for termination under section 232.41(2)(d), which, although not relied on by the trial court, would have justified termination”).”

In the Interest of Robbins, 230 N.W.2d 489 (Iowa 1975). “§ 232.41(2)(b), The Code. The other ground was an apparent attempt to paraphrase § 232.”

— Iowa Code § 232.41(2)(e) — 6 cases

In the Interest of Crooks, 262 N.W.2d 786 (Iowa 1978). “The appellant contends § 232.41(2)(e), The Code, 1975, which has since been repealed, was unconstitutionally vague on its face and as applied to the facts in this case, and also contends the grounds for termination stated in that statute were not established.”

— Iowa Code § 232.41(b) — 1 case

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