In the Interest of J.T., Minor Child

IN THE COURT OF APPEALS OF IOWA
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No. 25-2073
Filed June 24, 2026
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In the Interest of J.T., Minor Child,
K.T., Mother,
Appellant.
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Appeal from the Iowa District Court for Muscatine County,
The Honorable Gary P. Strausser, Judge.
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AFFIRMED
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Larry J. Brock, Washington, attorney for appellant mother.

Brenna Bird, Attorney General, and Tamara Knight, Assistant Attorney
General, attorneys for appellee State.

Jean Pfeiffer, Muscatine, attorney and guardian ad litem for minor child.
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Considered without oral argument
by Chicchelly, P.J., Buller, J., and Bower, S.J.
Opinion by Chicchelly, P. J.

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CHICCHELLY, Presiding Judge.

A mother1 appeals the termination of her parental rights to J.T., born
in 2023. She argues the juvenile court erred when it declined to grant her a
six-month extension to work towards reunification instead of terminating her
parental rights. Upon our review, we affirm the juvenile court’s termination
of the mother’s parental rights.

BACKGROUND FACTS AND PROCEEDINGS
The family came to the attention of the Iowa Department of Health
and Human Services (HHS) in October 2023. The child had been born
prematurely and spent the first month of his life in the neonatal intensive care
unit. The child had breathing problems, high blood pressure, and a hole in
his heart. After being released from the hospital, the child was not taken to
follow-up medical appointments. HHS initiated a child protective
assessment.

The mother admitted she had not taken the child to follow-up medical
appointments. She cited changing her phone number, forgetting to make the
appointments, and a lack of reliable transportation as reasons for missing the
appointments. HHS had additional concerns with the mother’s care,
including co-sleeping with the child who has breathing problems. The
investigation resulted in a founded child protective assessment for failure to
provide adequate medical care, and the mother agreed to a safety plan.

HHS later became aware of additional concerns regarding the
mother’s treatment of the child. They received allegations that the mother
screamed and cursed at the child when he cried. When HHS confronted the

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The father’s parental rights were also terminated, but he is not a party to this
appeal.

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mother about these allegations, she admitted to doing so. The safety plan
was then amended to require the child’s grandmother to reside with them
and supervise interactions between the mother and child. But the mother
objected to this option, instead preferring that the child be placed outside the
home. So, the mother signed a voluntary placement agreement, and the child
was placed in foster care.

In November 2023, the State filed a petition alleging the child to be a
child in need of assistance (CINA). The State alleged grounds under Iowa
Code section 232.96A(2), (3)(b), (5), (11), and (14). At the adjudication
hearing, the juvenile court found J.T. to be a CINA under all grounds alleged
by the State. The mother and father of the child were required to participate
in services and random drug testing.

As of September 2024, the father was participating in services, but the
mother’s participation was inconsistent. The juvenile court confirmed its
CINA adjudication and expressed concern about the mother’s
demonstration of her ability to provide for the child’s basic needs. By
November, the father’s participation in services had stopped. Meanwhile,
the mother’s participation in services had increased, but the juvenile court
characterized her participation as inconsistent. Additionally, the mother
refused to address her mental health concerns.

In February 2025, due to this lack of progress, the State filed a petition
to terminate the mother and father’s parental rights. It alleged grounds for
termination under Iowa Code section 232.116(1)(e), (g), and (h) (2025) as to
both parents. Additionally, the State alleged grounds under section
232.116(1)(i) as to the mother. At the termination hearing, the mother
requested a six-month extension in lieu of termination of her parental rights.

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The juvenile court denied that request and terminated the mother’s parental
rights under section 232.116(1)(g) and (h). The mother appeals.

STANDARD OF REVIEW
We review termination-of-parental-rights proceedings de novo. In re
Z.P., 948 N.W.2d 518, 522 (Iowa 2020) (per curiam); In re L.T., 924 N.W.2d
521, 526 (Iowa 2019). We give weight to the juvenile court’s factual findings,
especially regarding witness credibility, but we are not bound by them. In re
M.D., 921 N.W.2d 229, 232 (Iowa 2018). The paramount concern in a
termination proceeding is the child’s best interests. Id.

DISCUSSION
Our review follows a three-step analysis. See In re P.L., 778 N.W.2d 33,
39 (Iowa 2010). First, we consider whether statutory grounds for termination
of the parent’s rights exist under Iowa Code section 232.116(1). Id. Second,
we consider whether termination of the parent’s rights is in the child’s best
interests. Id. Third, we consider whether any of the exceptions to
termination should be applied. Id. But when the parent does not raise a claim
relating to any of the three steps, we need not address that step and instead
limit our review to the specific claims presented. See id. at 40 (recognizing
we need not consider a step the parent does not challenge). Because the
mother’s sole argument on appeal is that the juvenile court should have
granted her a six-month extension in lieu of terminating her parental rights,
we confine our review to that issue. However, we note that upon our review
we find the State has met its burden to prove the grounds for termination and
that termination was in the child’s best interests.

To grant a six-month extension, the juvenile court must be able to
“enumerate the specific factors, conditions, or expected behavioral changes”

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providing a basis to determine the children will be able to return to the parent
at the end of the additional six months. Iowa Code § 232.104(2)(b). The
burden is not on the State to prove an extension is not appropriate, as the
mother asserts. Rather, the court needs evidence to support a finding that
the mother would be able to care for the children within six months. “The
judge considering [an extension] should however constantly bear in mind
that, if the plan fails, all extended time must be subtracted from an already
shortened life for the children in a better home.” In re A.A.G., 708 N.W.2d
85, 92 (Iowa Ct. App. 2005) (citation omitted).

The State contends that the mother’s petition fails to adequately set
forth an argument from which we could decide the issues presented without
engaging in advocacy ourselves. The State emphasizes that the mother “has
not challenged any specific facts asserted” and “has not addressed how the
cited authority as applied to the facts of her case would demonstrate the need
for removal would no longer exist if she was granted additional time.” We
tend to agree with these observations. However, assuming without deciding
that the mother adequately briefed the six-month-extension issue, we
proceed to the merits.

Upon our de novo review of the record, we find that a six-month
extension is not warranted. The mother made very limited progress towards
reunification and did not meaningfully address her failure to provide
adequate care for the child when he was in her custody. “Parenting cannot
be turned off and on like a spigot. It must be constant, responsible, and
reliable.” In re T.J.O., 527 N.W.2d 417, 422 (Iowa Ct. App. 1994) (citation
omitted). As the juvenile court noted, the mother has not attended any of
the child’s medical appointments or therapy sessions and is not aware of the
child’s needs in those regards or how to meet those needs. Among other

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concerning behaviors are the mother questioning whether the child ate baby
food when he was twenty months old and her refusal to maintain compliance
with medication for her own mental-health needs. We acknowledge that the
mother made some progress in participating with HHS during the last few
months before termination, but our court has consistently held that last-
minute changes do not warrant six-month extensions. See In re L.A., 20
N.W.3d 529, 536 (Iowa Ct. App. 2025) (en banc) (collecting cases where
“eleventh hour” efforts did not warrant an extension). The mother has not
demonstrated her ability to be a responsible parent for the child enough to
deny him permanency. Accordingly, we affirm the juvenile court’s decision
not to grant a six-month extension.

AFFIRMED.

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