In the Interest of A.M., Minor Child, A.M., Father, Appellant, J.O., Mother, Appellant, State of Iowa, Appellee

Summary

On further review, the Supreme Court of Iowa vacated the court of appeals' reversal and reinstated the juvenile court's termination of both parents' rights to their one-year-old daughter under Iowa Code section 232.116(1)(h). Although the case lacked the usual precursors to termination—no abuse, substance abuse, domestic violence, or overt neglect—the court held clear and convincing evidence showed the child could not be returned to parents with intellectual limitations who, after a year of services, still could not care for her without ongoing DHS oversight and conceded they would need regular drop-in help. Termination was in the child's best interests because she was adoptable, bonded with and thriving in her maternal grandparents' prospective adoptive placement, and entitled to permanency, and no section 232.116(3) exception applied. Reviewing de novo, the court stressed that individually trivial incidents observed during supervised visits must be weighed in context and that children cannot be made to wait indefinitely for parents to learn to parent.