## Facts

- The State sought termination of K.F.’s parental rights to her daughter, Kristi, after years of child-in-need-of-assistance proceedings and reunification services.
- K.F. was diagnosed with paranoid schizophrenia and, over about four and one-half years, was involuntarily committed to mental-health facilities eleven times.
- Kristi (age nine at the termination hearing) experienced repeated foster-care and emergency placements tied to K.F.’s hospitalizations, resulting in prolonged instability.
- A treating psychiatrist testified K.F.’s illness was cyclical: periods of functioning on medication followed by periods of stopping medication, losing contact with reality, and becoming potentially violent.
- The psychiatrist further opined that absent external pressure or supervision, K.F. was likely to stop taking medication and quickly become psychotic again.
- The juvenile court terminated K.F.’s parental rights under Iowa Code § 232.116(5), finding Kristi could not be returned to K.F.’s custody.
- The court of appeals reversed, emphasizing K.F.’s recent progress and a reunification goal; on further review, the supreme court considered whether termination should stand.

## Issues

1. Whether the State proved by clear and convincing evidence under Iowa Code § 232.116(5) that Kristi could not be returned to K.F.’s custody without remaining a child in need of assistance.
2. Whether, and to what extent, a parent’s chronic mental illness may support termination when mental disability alone is insufficient.
3. Whether Kristi’s best interests, including her need for long-term stability and permanency, favored termination rather than continued reunification efforts.

## Decision

- The Iowa Supreme Court granted further review, vacated the court of appeals decision, and affirmed the juvenile court’s termination order.
- The Court held the statutory ground for termination under Iowa Code § 232.116(5) was proven by clear and convincing evidence.
- The Court concluded Kristi could not be safely returned to K.F.’s custody given the established pattern of relapse and likely future noncompliance with medication.
- The Court determined termination served Kristi’s long-range best interests by providing permanency and stability.

## Legal Principles

- Appellate review of termination proceedings is de novo, with weight given to the juvenile court’s fact findings, particularly witness credibility determinations.
- Statutory grounds for termination must be established by clear and convincing evidence.
- The child’s best interests control; courts consider long-range as well as immediate interests, and past parental performance is probative of likely future care.
- Mental disability, standing alone, does not justify termination, but it is a proper factor and may be determinative when it contributes to an inability to parent safely and consistently.

## Conclusion

The court affirmed termination of K.F.’s parental rights because the record showed, by clear and convincing evidence, that her chronic schizophrenia and recurrent relapses made Kristi’s safe return unlikely and that Kristi’s long-term welfare required permanency rather than continued uncertainty.


In re Interest of K.F., 437 N.W.2d 559 (Iowa 1989)