IN THE INTEREST OF S.K., Minor Child, A.L., Mother, Appellant.
from the Iowa District Court for Pottawattamie County, Scott
Strait, District Associate Judge.
mother appeals the termination of her parental rights.
M. Rohling of Rohling Law, PLLC, Council Bluffs, for
J. Miller, Attorney General, and Meredith L. Lamberti,
Assistant Attorney General, for appellee State.
C. Goaley, Council Bluffs, attorney and guardian ad litem for
Considered by Mullins, P.J., Bower, J., and Blane, S.J.
mother, Ashley, did not sufficiently address her
substance-abuse issues to resume care of her child, S.K., and
termination of her parental rights is supported under Iowa
Code section 232.116(1)(h) (2018).
review termination proceedings de novo. In re A.B.,
815 N.W.2d 764, 773 (Iowa 2012). "Our primary concern .
. . has always been the best interests of the
child[ren]." In re L.T., 924 N.W.2d 521, 529
(Iowa 2019). We begin by considering the statutory grounds.
"When the juvenile court terminates parental rights on
more than one statutory ground, we may affirm the juvenile
court's order on any ground we find supported by the
record." A.B., 815 N.W.2d at 774. The juvenile
court terminated Ashley's parental rights under
paragraphs (b), (e), (g), (h), and (l) of Iowa Code
section 232.116(1). We consider the grounds of section
232.116(1)(h), which allows the court to terminate parental
rights if all of the following factors are met:
(1) The child is three years of age or younger.
(2) The child has been adjudicated a child in need of
assistance pursuant to section 232.96.
(3) The child has been removed from the physical custody of
the child's parents for at least twelve of the last
eighteen months, or for the last twelve consecutive months
and any trial period at home has been less than thirty days.
(4) There is clear and convincing evidence that at the
present time the child cannot be returned to the custody of
the child's ...