In the Interest of A.M., Minor Child

IN THE COURT OF APPEALS OF IOWA No. 22-0724 Filed August 3, 2022 IN THE INTEREST OF A.M., Minor Child, S.M., Mother, Appellant. ________________________________________________________________ Appeal from the Iowa District Court for Cerro Gordo County, Adam D. Sauer, District Associate Judge. A mother appeals the termination of her parental rights to her child. AFFIRMED. William T. Morrison, Mason City, for appellant mother. Thomas J. Miller, Attorney General, and Ellen Ramsey-Kacena, Assistant Attorney General, for appellee State. Michael Moeller of Sorenson & Moeller Law Office, Clear Lake, attorney and guardian ad litem for minor child. Considered by May, P.J., and Greer and Chicchelly, JJ. 2 MAY, Presiding Judge. A mother appeals the termination of her parental rights to her child, A.M. On appeal, she challenges the statutory grounds for termination1 and whether termination is in A.M.’s best interest. She also urges we should apply permissive exceptions to termination. And she claims the juvenile court erred by denying her motion for new trial. We affirm. We review termination proceedings de novo. In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). “We will uphold an order terminating parental rights where there is clear and convincing evidence of the statutory grounds for termination. Evidence is clear and convincing when there is no serious or substantial doubt as to the correctness of the conclusions of law drawn from the evidence.” In re T.S., 868 N.W.2d 425, 431 (Iowa Ct. App. 2015) (internal citation omitted). We generally use a three-step analysis to review the termination of a parent’s rights. In re A.S., 906 N.W.2d 467, 472 (Iowa 2018). We must determine: (1) whether grounds for termination have been established, (2) whether termination is in the child’s best interest, and (3) whether we should exercise any of the permissive exceptions to termination. Id. at 472–73. Finally, we consider any additional arguments raised by the parent. 1 The mother makes a passing reference to the sufficiency of the State’s efforts towards reunification. Setting aside error-preservation issues, we conclude the mother has failed to adequately develop an argument for our review. See State v. Louwrens, 792 N.W.2d 649, 650 n.1 (Iowa 2010) (“Moreover, passing reference to an issue, unsupported by authority or argument, is insufficient to raise the issue on appeal.”). 3 So we begin with the mother’s challenge to the statutory grounds. The juvenile court terminated the mother’s rights pursuant to Iowa Code section 232.116(1)(f) (2021). Paragraph (f) authorizes termination when: (1) The child is four years of age or older. (2) The child has been adjudicated a child in need of assistance pursuant to section 232.96. (3) The child has been removed from the physical custody of the child’s parents for at least twelve of the last eighteen months, or for the last twelve consecutive months and any trial period at home has been less than thirty days. (4) There is clear and convincing evidence that at the present time the child cannot be returned to the custody of the child’s parents as provided in section 232.102. Iowa …

Original document
Source: All recent Immigration Decisions In All the U.S. Courts of Appeals