Supreme Court of Iowa

In the Interest of L.t., A.t., and D.t., Minor Children, K.t., Mother, Appellant.

March 1, 2019924 N.W.2d 521

Summary

The court held that the juvenile court abused its discretion by refusing to reopen the termination record after an approximately twenty-month delay, particularly because the mother sought to present current evidence directly relevant to sobriety, housing, and employment. The court also held that DHS's reasonable-efforts obligation continues until entry of a final written termination order, although the efforts need not always be directed toward reunification and depend on the children's best interests. The court vacated the court of appeals decision, reversed the juvenile court's termination order, and remanded for an expedited reopening of the record and reconsideration of the termination petition. No separate opinions were filed.