parental rights, appellate practice

Iowa case law summary by Attorney Richard Clem: parental rights, appellate practice.

In the Interest OF I.M., Minor Child, I.M., Mother, C.M., Grandmother. IA parental rights, appellate practice.

The mother and grandmother both appealed a Polk County order terminating the mother's parental rights, as well as the subsequent disposition order, in which the child was placed with a third party. In particular, the mother appealed that the child should have been placed with her as a relative placement preference.

Unfortunately, neither the mother nor the grandmother ordered a transcript of the disposition proceedings. (There apparently was a transcript of the termination portion of the proceedings.)

Citing Iowa Rule of Appellate Procedure 6.803 and In re F.W.S., 698 N.W.2d 134, 135–36 (Iowa 2005), the appeals court held that the issue was waived and affirmed the trial court's judgment.

No. 13-0821 (Iowa Ct. App. Aug. 27, 2014)

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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