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


Procedural:The state and the guardian ad litem sought review of the decision of the Court of Appeals (Iowa), which reversed the judgment of the district court terminating the appellant mother's parental rights to her daughter due to the mother's chronic mental illness after the daughter had been adjudicated a child in need of assistance (CINA) under Iowa Code.

Facts:The State (P) petitioned the court to terminate the parental rights of K.F. (D). D suffered from schizophrenia, paranoid subtype. She had been subject to frequent involuntary commitments. Her daughter had been in foster care for four and one-half years. The trial court terminated D's parental rights. The court of appeals reversed. P appeals.

Issue: Whether or not mental illness standing alone enough of a reason to terminate a mother child relationship?

Rule:Clear and convincing evidence, which established that mother suffered from schizophrenia and had been subject to 11 involuntary commitments due to her mental illness and that her daughter had spent four and one-half years of her young life in out-of-home placements and that mother would not remain in remission if allowed to resume daughter's care, supported termination of mother's parental rights.

Holding: Yes. Judgment reversed. The District Court, Scott County, Arlen J. Van Zee, Associate Judge, entered a judgment severing a mother-child relationship. The Court of Appeals reversed, and further review was taken. The Supreme Court, Neuman, J., held that clear and convincing evidence, which established that mother suffered from schizophrenia and had been subject to 11 involuntary commitments due to her mental illness and that her daughter had spent four and one-half years of her young life in out-of-home placements and that mother would not remain in remission if allowed to resume daughter's care, supported termination of mother's parental rights.

Analysis: Mental illness standing alone is an insufficient reason to terminate parental rights, but is a proper factor to consider if it contributes to a person's inability to parent. The evidence was clear and convincing that D's inability to parent was caused by her mental illness.