Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the juvenile court terminating the parental rights with respect to two Indian children under the Indian Child Welfare Act (ICWA), 25 U.S.C. 1903(4), and Iowa Code chapter 232B (Iowa ICWA), holding that the juvenile court erred in considering the best interests of the children on the narrow question of transfer to the tribal court.In 2018, the State commenced child-in-need-of-assistance proceedings involving the older child, and in 2019, the Sate commenced CINA proceedings against the younger child. The Omaha Tribe of Nebraska & Iowa (Tribe) was granted intervention and subsequently filed a motion to transfer the case to tribal court. The juvenile court denied the motion to transfer on the ground that it would not be in the best interests of the children. The court then terminated the parental rights of both parents. The Supreme Court reversed, holding that the juvenile court erred in denying the Tribe's motion to transfer jurisdiction. View "In re T.F." on Justia Law

The Supreme Court reversed the order of the juvenile court terminating Father's parental rights to his child, holding that the juvenile court erred when it terminated Father's parental rights because the child was not adjudicated a child in need of assistance (CINA).The juvenile court ultimately concluded that it could terminate Father's parental rights because the child was previously adjudicated CINA in a previous CINA proceeding that resulted in a guardianship. The court then terminated Father's rights under Iowa Code 232.116(1)(f) and (g). The Supreme Court reversed and remanded the case for further proceedings, holding that a prior CINA adjudication in a closed case cannot be utilized to meet the statutory requirements of 232.116(1)(f) and (g) for a second CINA proceeding. View "In re L.B." on Justia Law

The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court's order terminating a guardianship of a minor child that was established with parental consent, holding that there was no error.Young parents consented to a temporary guardianship for the paternal grandparents to serve as guardians of their minor daughter so that the parents could establish stability in their lives. After achieving that stability, Mother sought to terminate the guardianship. The juvenile court entered a termination order, concluding that the child's long-term interests warranted terminating the guardianship. The Supreme Court affirmed, holding that the juvenile court properly terminated the guardianship and placed the child in Mother's care pending modification of the parents' dissolution decree to establish physical and legal custody. View "In re Guardianship of L.Y." on Justia Law

The Supreme Court affirmed the order of the juvenile court terminating Father's parental rights to his child, holding that the juvenile court did not err in terminating Father's parental rights.The juvenile court concluded that the State proved the grounds for termination and terminated Father's parental rights. Father's counsel filed a motion for belated appeal, which the Supreme Court granted. The Supreme Court then affirmed, holding that the State proved by clear and convincing evidence that the bases for termination under both Iowa Code 232.116(1)(3) and 232.116(1)(h) were satisfied and that no exceptions in Iowa Code 232.116(3) applied to preclude the termination. View "In re W.T." on Justia Law

The Supreme Court vacated in part the decision of the court of appeals affirming the district court's ruling that Iowa Code chapter 411 ordinary disability benefits are marital property, holding that chapter 411 ordinary disability benefits replace income that an individual would have earned if not for an injury causing the disability and should be treated as income rather than as property.The district court entered a dissolution decree dissolving the marriage of Matt and Karri Miller. The district court determined that Matt's chapter 411 ordinary disability benefit was marital property subject to division. The court of appeals affirmed. At issue before the Supreme Court was whether Matt's future disability benefit was income or property. The Supreme Court vacated in part the court of appeals' decision and let the rest of the court of appeals' opinion stand on the remaining issues, holding that Matt's future disability benefit is a replacement for income and not part of the marital pot to be divided upon dissolution. View "In re Marriage of Miller" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the juvenile court's permanency order transferring sole legal custody of the child in this case to Father, holding that there was convincing evidence to show that the child could safely be transitioned to Mother's care at the time of the permanency hearing.The State initiated a child-in-need-of-assistance proceeding due to the parents' inability to coparent. At the time, Mother was the primary custodial parent. Mother participated in services to reunify with the child and showed progress, but the juvenile court determined it was not safe to return the child to Mother's home and entered a permanency order transferring sole legal custody of the child to Father. The court of appeals reversed. The Supreme Court affirmed, holding that there was convincing evidence to show the child could safely be transitioned to Mother's care at the time of the permanency hearing. View "In re D.M." on Justia Law

The Supreme Court reversed the order of the district court striking down sections 99 and 100 of House File 766, which added funding conditions prohibiting abortion providers from participating in two federally funded educational grant programs directed at reducing teenage pregnancy and promoting abstinence, holding that any conditions premised on providing abortions cannot be considered unconstitutional.Planned Parenthood of the Heartland (PPH) was a former grantee of both grants and, upon the passage of sections 99 and 100, became ineligible to receive funding. PPH brought a declaratory judgment action arguing that the Act violated its rights to equal protection, due process, free speech, and free association under the Iowa Constitution. The district court granted summary judgment for PPH and enjoined enforcement of the legislative enactments. The Supreme Court affirmed, holding (1) the conditions were rationally related to the classification selected by the general assembly; and (2) where abortion providers have no constitutional right to perform abortions, the unconstitutional conditions doctrine did not prohibit the State form barring abortion providers from receiving the funding at issue. View "Planned Parenthood of the Heartland, Inc. v. Reynolds" on Justia Law

The Supreme Court reversed the adjudication of the juvenile court adjudicating Mother's fourth child, A.W., a child in need of assistance (CINA), holding that the State failed to offer clear and convincing evidence that A.W. was at imminent risk of harm from Mother's failure to "exercise a reasonable degree of care in supervising" A.W., as required to support adjudication under Iowa Code 232.2(6)(c)(2).A.W. was born in April 2020. On April 2, 2021, the Supreme Court reversed the termination of Mother's parental rights to her three older children. The juvenile court adjudicated A.W. as a CINA based on two grounds - Iowa Code 232.2(6)(n) and section 232.2(6)(c)(2). The court of appeals reversed the adjudication based on section 232.2(6)(n) but affirmed on section 232.2(6)(c)(2) grounds. The Supreme Court reversed, holding that A.W. should not have been adjudicated CINA, and therefore, the juvenile court erred. View "In re A.W." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court terminating the parental rights of Father to his child and denying the State's petition to terminate Mother's parental rights and instead entering a permanency order appointing Grandmother of one of the boys as the guardian for both, holding that the juvenile court should have terminated Mother's parental rights.Father appealed the termination of his rights, but his notice of appeal was untimely filed. Mother appealed the permanency order, asking the Court to direct the State to continue reunification efforts. The State also appealed, challenging the juvenile court's disposition as to Mother. The Supreme Court reversed as to Mother and otherwise affirmed, holding (1) as to Mother, guardianship was not a proper permanency plan, and the juvenile court erred in denying termination; and (2) because Father's late filing of an appeal was beyond his control, this Court addresses his appeal, and the juvenile court did not err in terminating Father's parental rights. View "In re W.M." on Justia Law

The Supreme Court reversed the termination of parental rights as to Mother but not as to Father, holding that the juvenile court erred in finding each required element for a termination of Mother's custody under Iowa Code Ann. 232.116(1)(f) and (h).At issue was the termination of the parental rights of Mother to her three children and the termination of the parental rights of Father of one of the children. Both parties appealed, but Father filed his petition two days late. The Supreme Court affirmed in part and reversed in part, holding (1) this Court recognizes delayed appeals in termination of parental rights cases under certain limited circumstances; (2) the State did not meet its burden of proving that the children could not be returned to Mother's custody at the time of the adjudication; and (3) the juvenile court properly terminated Father's parental rights as to his child. View "In re A.B." on Justia Law