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In re L.M.

Court of Appeals of Iowa

August 15, 2018

IN THE INTEREST OF L.M., Minor Child, K.S., Mother, Appellant, T.M., Father, Appellant.

          Appeal from the Iowa District Court for Dallas County, Virginia Cobb, District Associate Judge.

         The mother and father separately appeal the termination of their parental rights.

          Robb D. Goedicke of Cooper, Goedicke, Reimer & Reese Law Firm, PC, West Des Moines, for appellant mother.

          Nicholas J. Einwalter, Des Moines, for appellant father.

          Thomas J. Miller, Attorney General, and Anagha Dixit, Assistant Attorney General, for appellee State.

          Kayla A. Stratton of Juvenile Public Defender Office, Des Moines, guardian ad litem for minor child.

          Considered by Potterfield, P.J., and Bower and McDonald, JJ.

          POTTERFIELD, PRESIDING JUDGE.

         The juvenile court terminated the mother's and father's parental rights to their child, L.M., pursuant to Iowa Code section 232.116(1)(d) and (h) (2017). The mother only nominally appeals the termination, while the father challenges the sufficiency of the evidence supporting one of the grounds for termination, whether termination was in the child's best interests, and the juvenile court's determination no permissive factor should be applied to save the parent-child relationship.

         I. Standard of Review.

         We review termination-of-parental-rights proceedings de novo. In re P.L., 778 N.W.2d 33, 40 (Iowa 2010).

         II. Mother's Appeal.

         Although the mother filed an appellate brief in this matter, she does not actually challenge any part of the juvenile court's ruling. She asks that we reverse the termination of parental rights, but she offers no legal grounds upon which we may do so and does not challenge any of the juvenile court's findings of fact. Her appellate brief contains no argument and no legal authority. We recognize that the appeal of a termination order is an expedited process, see Iowa R. App. P. 6.201(1), but the parent is still required to raise specific issues. The mother's failure to make a specific argument waives error. See In re C.B., 611 N.W.2d 489, 492 (Iowa 2000) ("We have ...


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