Justia Family Law Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the court of appeals in this dissolution of marriage proceeding, holding that, contrary to the judgment of the lower court, Husband's concealment of a certain pension was intrinsic fraud.Throughout negotiation within the proceedings below, Husband failed to disclose his GE retirement pension. After Wife discovered the omission five years later she brought this action seeking to modify the dissolution decree by awarding her part of the pension, alleging extrinsic fraud. In response, Husband argued that the alleged fraud was intrinsic and that reasonable diligence on Wife's part would have led to the discovery of his pension within one year after entry of the order. The district court entered judgment for Wife. The court of appeals reversed in part, holding that the district court properly found the fraud was extrinsic but erred in determining that Wife would not have found the pension with reasonable diligence. The Supreme Court vacated in part, holding (1) Husband's concealment of the GE pension was intrinsic fraud; and (2) Wife would have discovered the pension within one year with reasonable diligence. View "In re Marriage of Hutchinson" on Justia Law

The Supreme Court affirmed the ruling of the juvenile court that the Indian Child Welfare Act (ICWA) did not apply to the termination of parental rights proceedings below, holding that the juvenile court did not err in determining that Z.K. was not an "Indian child" under ICWA.After holding a hearing on the applicability of ICWA the juvenile court concluded that ICWA remained inapplicable to Z.K. Turning to the merits, the juvenile court found that the State's reasonable efforts to avoid the out-of-home placement had been unsuccessful and proceeded to terminate the parents' parental rights to Z.K. The court of appeals affirmed. The Supreme Court affirmed, holding that the juvenile court properly determined that Z.K. did not meet the definition of "Indian child" under the applicable ICWA statutes. View "In re Z.K." on Justia Law

The Supreme Court further modified a hybrid traditional and rehabilitative alimony award that the court of appeals modified in this case, holding that this Court hereby adopts transitional alimony as another tool to do equity in calculating spousal support.In this divorce action, the district court entered a decree dissolving the parties' seventeen-year marriage, ordering shared custody and physical care of the children, and diving the marital property. On appeal, the court of appeals increased the spousal support award and recalculated Husband child support obligation. On appeal, Husband argued that the increase in the spousal support award and duration was excessive and unnecessary. The Supreme Court affirmed the decision as modified, holding that the alimony is modified as to the amount and duration and that this modification required a recalculation of child support. View "In re Marriage of Pazhoor" on Justia Law

The Supreme Court reversed the judgment of the juvenile court terminating the parental rights with respect to two Indian children under the Indian Child Welfare Act (ICWA), 25 U.S.C. 1903(4), and Iowa Code chapter 232B (Iowa ICWA), holding that the juvenile court erred in considering the best interests of the children on the narrow question of transfer to the tribal court.In 2018, the State commenced child-in-need-of-assistance proceedings involving the older child, and in 2019, the Sate commenced CINA proceedings against the younger child. The Omaha Tribe of Nebraska & Iowa (Tribe) was granted intervention and subsequently filed a motion to transfer the case to tribal court. The juvenile court denied the motion to transfer on the ground that it would not be in the best interests of the children. The court then terminated the parental rights of both parents. The Supreme Court reversed, holding that the juvenile court erred in denying the Tribe's motion to transfer jurisdiction. View "In re T.F." on Justia Law

The Supreme Court reversed the order of the juvenile court terminating Father's parental rights to his child, holding that the juvenile court erred when it terminated Father's parental rights because the child was not adjudicated a child in need of assistance (CINA).The juvenile court ultimately concluded that it could terminate Father's parental rights because the child was previously adjudicated CINA in a previous CINA proceeding that resulted in a guardianship. The court then terminated Father's rights under Iowa Code 232.116(1)(f) and (g). The Supreme Court reversed and remanded the case for further proceedings, holding that a prior CINA adjudication in a closed case cannot be utilized to meet the statutory requirements of 232.116(1)(f) and (g) for a second CINA proceeding. View "In re L.B." on Justia Law

The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court's order terminating a guardianship of a minor child that was established with parental consent, holding that there was no error.Young parents consented to a temporary guardianship for the paternal grandparents to serve as guardians of their minor daughter so that the parents could establish stability in their lives. After achieving that stability, Mother sought to terminate the guardianship. The juvenile court entered a termination order, concluding that the child's long-term interests warranted terminating the guardianship. The Supreme Court affirmed, holding that the juvenile court properly terminated the guardianship and placed the child in Mother's care pending modification of the parents' dissolution decree to establish physical and legal custody. View "In re Guardianship of L.Y." on Justia Law

The Supreme Court affirmed the order of the juvenile court terminating Father's parental rights to his child, holding that the juvenile court did not err in terminating Father's parental rights.The juvenile court concluded that the State proved the grounds for termination and terminated Father's parental rights. Father's counsel filed a motion for belated appeal, which the Supreme Court granted. The Supreme Court then affirmed, holding that the State proved by clear and convincing evidence that the bases for termination under both Iowa Code 232.116(1)(3) and 232.116(1)(h) were satisfied and that no exceptions in Iowa Code 232.116(3) applied to preclude the termination. View "In re W.T." on Justia Law

The Supreme Court vacated in part the decision of the court of appeals affirming the district court's ruling that Iowa Code chapter 411 ordinary disability benefits are marital property, holding that chapter 411 ordinary disability benefits replace income that an individual would have earned if not for an injury causing the disability and should be treated as income rather than as property.The district court entered a dissolution decree dissolving the marriage of Matt and Karri Miller. The district court determined that Matt's chapter 411 ordinary disability benefit was marital property subject to division. The court of appeals affirmed. At issue before the Supreme Court was whether Matt's future disability benefit was income or property. The Supreme Court vacated in part the court of appeals' decision and let the rest of the court of appeals' opinion stand on the remaining issues, holding that Matt's future disability benefit is a replacement for income and not part of the marital pot to be divided upon dissolution. View "In re Marriage of Miller" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the juvenile court's permanency order transferring sole legal custody of the child in this case to Father, holding that there was convincing evidence to show that the child could safely be transitioned to Mother's care at the time of the permanency hearing.The State initiated a child-in-need-of-assistance proceeding due to the parents' inability to coparent. At the time, Mother was the primary custodial parent. Mother participated in services to reunify with the child and showed progress, but the juvenile court determined it was not safe to return the child to Mother's home and entered a permanency order transferring sole legal custody of the child to Father. The court of appeals reversed. The Supreme Court affirmed, holding that there was convincing evidence to show the child could safely be transitioned to Mother's care at the time of the permanency hearing. View "In re D.M." on Justia Law

The Supreme Court reversed the order of the district court striking down sections 99 and 100 of House File 766, which added funding conditions prohibiting abortion providers from participating in two federally funded educational grant programs directed at reducing teenage pregnancy and promoting abstinence, holding that any conditions premised on providing abortions cannot be considered unconstitutional.Planned Parenthood of the Heartland (PPH) was a former grantee of both grants and, upon the passage of sections 99 and 100, became ineligible to receive funding. PPH brought a declaratory judgment action arguing that the Act violated its rights to equal protection, due process, free speech, and free association under the Iowa Constitution. The district court granted summary judgment for PPH and enjoined enforcement of the legislative enactments. The Supreme Court affirmed, holding (1) the conditions were rationally related to the classification selected by the general assembly; and (2) where abortion providers have no constitutional right to perform abortions, the unconstitutional conditions doctrine did not prohibit the State form barring abortion providers from receiving the funding at issue. View "Planned Parenthood of the Heartland, Inc. v. Reynolds" on Justia Law