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Neutral Court Opinion Apr 21, 2026

In the Interest of Z.P., Minor Child

── In the Interest of Z.P., Minor Child ── Court: Court of Appeals of Iowa Date: April 15, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 26-0312 Filed April 15, 2026 _______________ In the Interest of Z.P., Minor Child, M.P., Mother, Appellant. _______________ Appeal from the Iowa District Court for Fayette County, The Honorable Linnea M.N. Nicol, Judge. _______________ AFFIRMED _______________ Kristin R. Schiller Herman, Calmar, attorney for appellant mother. Brenna Bird, Attorney General, and Lisa Jeanes, Assistant Attorney General, attorneys for appellee State. Kimberly S. Lange of the State Public Defender’s Office, Waterloo, attorney and guardian ad litem for minor child. _______________ Considered without oral argument by Tabor, C.J., and Chicchelly and Sandy, JJ. Opinion by Sandy, J. 1 SANDY, Judge. These proceedings arise from the child-in-need-of-assistance (CINA) adjudication and subsequent termination-of-parental-rights (TPR) involving a mother and her son, Z.P., born August 2024. The mother argues termination is not in the child’s bests interests and, alternatively, that an exception to termination should have been applied, that a guardianship should be established, and that the Iowa Department of Health and Human Services (HHS) failed to make reasonable efforts toward reunification. We affirm. BACKGROUND FACTS AND PROCEEDINGS Shortly after the child’s birth, concerns arose regarding the mother’s substance use. The record reflects that the mother self-reported intravenous methamphetamine use during pregnancy, including use shortly before the child’s birth. As a result, the child came to the attention of HHS and was initially subject to a safety plan following his birth before being formally removed from the mother’s custody by court order in September 2024. Following removal, the child was first placed with fictive kin and later transitioned to family foster care in April 2025, where he has remained. The child has never resided in the mother’s custody. In October 2024, the juvenile court adjudicated the child as in need of assistance based on concerns related primarily to the mother’s substance use and associated safety risks. The child was placed in the custody of HHS, and a permanency plan required the mother to engage in substance-use and mental-health treatment, submit to drug testing, and participate in services designed to address the adjudicatory harms. 2 HHS provided a range of reunification services, including multiple substance-use evaluations, inpatient- and outpatient-treatment opportunities, random drug testing, family-centered services, and housing and transportation assistance. The mother participated in services and completed inpatient treatment on more than one occasion. However, the record reflects an ongoing pattern of relapse and an inability to maintain sustained sobriety throughout the pendency of the case. The case proceeded through a series of review and permanency hearings. At one point, the juvenile court granted the mother an additional six months to work toward reunification based on partial progress, including completion of treatment. Despite that extension, the mother’s sobriety remained unstable. At the termination hearing, the mother acknowledged methamphetamine use as recently as the day before the hearing. In September 2025, the State filed a petition to terminate parental rights, alleging statutory grounds for termination under section 232.116(1)(h) and (l) (2025). A contested termination hearing was held in November 2025. The proceedings addressed only the mother’s parent
CourtListener · Apr 15, 2026
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