In the Interest of J.H., Minor Child

IN THE COURT OF APPEALS OF IOWA
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No. 25-2099
Filed February 25, 2026
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In the Interest of J.H., Minor Child,
B.W., Mother,
Appellant.
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Appeal from the Iowa District Court for Mahaska County,
The Honorable Patrick McAvan, Judge.
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AFFIRMED
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Rebecca L. Petig of Bierman & Petig, P.C., Grinnell, attorney for appellant
mother.

Brenna Bird, Attorney General, and Mackenzie Moran, Assistant Attorney
General, attorneys for appellee State.

Michael S. Fisher of Fisher Law Office, New Sharon, attorney and guardian
ad litem for minor child.
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Considered without oral argument
by Ahlers, P.J., and Buller and Sandy, JJ.
Opinion by Buller, J.

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BULLER, Judge.

A mother appeals termination of her parental rights to a child born in
2022. The putative father’s rights were also terminated, but he does not
appeal. So we focus on facts relating to the mother and the child. We reject
the mother’s best-interests claim and permissive-bond-exception argument
and affirm termination of her parental rights.

BACKGROUND FACTS AND PROCEEDINGS
The mother has struggled with a methamphetamine addiction and
cycled through the juvenile-court system for more than a decade. In brief, the
Iowa Department of Health and Human Services (HHS) has been
periodically involved with the mother since 2015 when HHS received a
report that the mother and her then-paramour were abusing substances while
caring for children. In two different cases—both centering on substance
abuse—four older children were removed and adjudicated as children in need
of assistance (CINAs). The mother’s parental rights to all four children were
subsequently terminated.1

In May 2022, the child at issue was born; both the child and the mother
tested positive for methamphetamine at birth. The mother admitted to using
methamphetamine while pregnant. She entered treatment, and the child was
left in her care. In August 2023, HHS received a report that the mother was
caring for the child while under the influence of methamphetamine. The
mother agreed to a safety plan and regular drug testing. After that safety plan

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Her rights to the three oldest children were terminated under Iowa Code
section 232.116(1)(f ) (2019). Her parental rights for the fourth child were terminated
under section 232.116(1)(h).

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fell through, the child was removed and adjudicated CINA the following
March.

HHS instructed the mother to obtain a substance-abuse evaluation and
follow subsequent recommendations, participate in drug testing when
requested, and complete program services. An assessment determined the
mother had severe methamphetamine use disorder. While the mother
engaged in substance-abuse services, she received conflicting information as
to the level of treatment required. Between February and August of 2024, the
mother tested positive for methamphetamine four times, and on two of those
occasions she was suspected of tampering with the test. In November, the
mother refused a hair test and then three days later tested negative for
substances in urine after violating the testing protocol. Despite this, HHS
credited the mother’s efforts toward bettering her mental health, seeking
housing, working part-time, and participating in outpatient substance-abuse
treatment; ultimately HHS recommended a six-month extension, which the
court granted in December 2024.

A little more than a week after the court granted her a six-month
extension, the mother admitted she had relapsed and used
methamphetamine in November. The following February, she tested positive
for methamphetamine from a hair test. She claimed this test detected her
November use, allegedly because her hair grows slowly as a medical
complication. In April, the mother failed to appear for a drug test, apparently
arriving at the wrong time. A couple of days later, HHS instructed the mother
to participate in another test, this time using a sweat patch. The mother
tampered with the sweat patch minutes after it was applied by removing it,
placing it on a pop bottle, freezing it for the duration of the testing period,
and reapplying the patch moments before it was removed for analysis.

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Despite the mother’s effort to thwart this test, it still came back positive for
methamphetamine.

In July, the mother was unsuccessfully discharged from outpatient
substance-abuse treatment. In August, the mother attended a substance-
abuse evaluation but failed to disclose the two positive drug tests she
disputed. That same month, the mother disclosed to HHS that her financial
situation had rapidly deteriorated: she had no income or savings, no means of
transportation, and relied on community assistance for rent.

As for her relationship with the child, a social worker testified that the
mother does a good job during her visits and there was never an issue with
the mother’s attendance. The social worker, a service provider, and the
guardian ad litem (GAL) all reported that the mother loves the child and the
two share a bond.

The child has lived with the same foster family since January 2025 and
is bonded with them and well adjusted. Service workers have observed the
child refer to the foster mother as “mommy.” And the foster parents are open
to adoption.

The county attorney, HHS, and the GAL all recommended
termination of parental rights. The juvenile court terminated the mother’s
parental rights under Iowa Code section 232.116(1)(g) and (h) (2025). And
she appeals, which we review de novo. See In re W.M., 957 N.W.2d 305, 312
(Iowa 2021).

DISCUSSION
The mother argues terminating her parental rights is not in the child’s
best interests and the juvenile court erred in not applying the permissive bond
exception. Because she does not dispute the grounds for termination, we

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need not address them. In re P.L., 778 N.W.2d 33, 40 (Iowa 2010). We take
each of her arguments in turn.

I. Best Interests

For her best-interests claim, the mother highlights her progress toward
housing and therapy and discounts the court’s concern about her substance
abuse. In our analysis, we give primary weight to the child’s safety, the best
placement for furthering long-term nurturing and growth, and the child’s
physical, mental, and emotional condition and needs. Iowa Code
§ 232.116(2). And on our review, we agree with the juvenile court that
termination is in the child’s best interests.

In short, the mother has prioritized her methamphetamine addiction
over the child. Her struggle with addiction stretches back more than a
decade, and her problems in this case echo the basis for termination of her
parental rights to her other children. Since November 2024, the mother
tested positive for methamphetamine (despite her effort at tampering), failed
to test on four other occasions, and only tested negative once under
suspicious circumstances. As the juvenile court noted, the mother “has been
unable to go more than a few months without using methamphetamine.” And
while we commend the mother for making progress toward improving her
mental health and housing, our case law makes clear that “unresolved,
severe, and chronic drug addiction can render a parent unfit to raise
children.” In re A.B., 815 N.W.2d 764, 776 (Iowa 2012). “No parent should
leave his small children in the care of a meth addict—the hazards are too
great.” Id. (citation omitted). And this record makes clear methamphetamine
continues to dominate the mother’s life. Meanwhile, the child is well-
integrated into the foster parents’ home. We affirm that termination is in the
child’s best interest.

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II. Permissive Bond Exception

In her petition on appeal, the mother makes passing references to her
strong bond with the child. “[A]s we have held before, ʻsprinkled mentions
of an issue’ are insufficient to raise legal claims for our consideration.” In re
K.P., No. 23-1661, 2024 WL 260885, at *3 (Iowa Ct. App. Jan. 24, 2024)
(citation omitted). But to the extent the claim is raised, we discern no basis
for relief. The bond between mother and child does not outweigh the danger
posed by the mother’s longstanding methamphetamine addiction or the
stability and safety afforded the child by termination and adoption. And so
the mother failed in her burden to prove this exception by clear and
convincing evidence. See Iowa Code § 232.116(3)(c).

AFFIRMED.

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