In the Interest of G.R., Minor Child

IN THE COURT OF APPEALS OF IOWA
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No. 25-2186
Filed March 11, 2026
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In the Interest of G.R., Minor Child,
D.R., Father,
Appellant.
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Appeal from the Iowa District Court for Cerro Gordo County,
The Honorable Adam D. Sauer, Judge.
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AFFIRMED
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Sabrina M. Dow, Mason City, attorney for appellant father.

Brenna Bird, Attorney General, and Michelle R. Becker, Assistant Attorney
General, attorneys for appellee State.

Cameron Sprecher, Mason City, attorney and guardian ad litem for
minor child.
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Considered without oral argument
by Tabor, C.J., and Badding and Langholz, JJ.
Opinion by Langholz, J.

1
LANGHOLZ, Judge.

Days after his birth in January 2025, a baby was removed from his
parents’ custody because he and his mother tested positive for
methamphetamine.1 The father—who had lost his parental rights to another
child just the year before and had a history of substance-use concerns—was
released from jail for the birth and awaiting placement at a community-based
corrections residential facility.

The child was adjudicated in need of assistance in March. At
disposition, the juvenile court found the family’s safety concerns had not
resolved and the child remained adjudicated. And throughout the
proceedings, the child has been in the care of a foster family who had already
adopted two of his biological siblings.

The father participated in a total of five visits with the son in March
and April. But he was incarcerated in the county jail for the next three months
and stopped cooperating with the Iowa Department of Health and Human
Services (“HHS”) and other service providers even when they tried to meet
with him at the jail. After the father was released from jail, HHS lost contact
entirely without an address or working phone number to reach him.

With little prospect for reunification, the State petitioned to terminate
the father’s parental rights in mid-July. The father finally reached out
expressing interest in starting visits with the son again in late August. And by
the November 2025 termination hearing, the father had made some progress,
including maintaining employment and participating in increased supervised

1
We avoid using the parties’ names to respect their privacy because this opinion—
unlike the juvenile court’s order—is public. Compare Iowa Code § 232.147(2) (2025), with
id. §§ 602.4301(2), 602.5110; see also Iowa Ct. R. 21.25.

2
visits with the son. But he was still placed at the residential facility with no
certain discharge date and, as he admitted, no immediate ability to care for
the son. The juvenile court found that the State established grounds for
termination under Iowa Code section 232.116(1)(h) (2025), that termination
was in the son’s best interest, and that none of the statutory exceptions
applied. So the court terminated the father’s parental rights.2

The father now appeals the juvenile court’s order terminating his
parental rights. He argues that the court should have dismissed the child-in-
need-of-assistance case and that HHS failed to provide reasonable efforts
toward reunification when he was incarcerated. But we cannot consider the
merits of either argument in this appeal.

We cannot consider the father’s challenge to the child-in-need-of-
assistance case because that was a separate case from this termination case.
See Iowa Code §§ 232.87, 232.111. The father did not challenge that
adjudication by filing a timely appeal of the dispositional order in that case.
See In re A.W., 464 N.W.2d 475, 477 (Iowa Ct. App. 1990) (noting that
“adjudication order standing alone was not a final appealable order” but
“became final” “when the dispositional order was entered”). He cannot
belatedly raise that challenge now in this appeal from the separate
termination case. See In re J.D.B., 584 N.W.2d 577, 581 (Iowa Ct. App. 1998).

The father’s challenge to HHS’s reasonable efforts toward
reunification while he was incarcerated is also too late. “In general, if a parent
fails to request other services at the proper time, the parent waives the issue
and may not later challenge it at the termination proceeding.” In re C.H.,

2
The mother’s parental rights were separately terminated a month before the
father’s termination hearing. She did not appeal.

3
652 N.W.2d 144, 148 (Iowa 2002). But the father failed to object to the
adequacy of HHS’s efforts before the termination hearing at a time when
additional services could have been considered. So we cannot consider this
request.

Because the father raises no other challenge to the juvenile court’s
order terminating his parental rights, we affirm.

AFFIRMED.

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