In re K.F. – Termination of Parental Rights
In re K.F., 437 N.W.2d 559 (Iowa 1989).
NATURE OF THE CASE: This case involved an appeal from a termination of a mother child relationship.
FACTS: Kristi’s mother suffers from schizophrenia and had been subject to eleven involuntary commitments due to her mental illness. At the time of this case Kristi had spent 4.5 years of her life in out of home placements. The mother has a serious case of the disease and she falls within a group of schizophrenics who become acutely ill within a week or two after stopping medication. When in remission, the mother is a polite, congenial, doting, and tidy homemaker. Even so she is never entirely free of the underlying problems and has moments of delusional behavior even when she appears to be normal. The mother concedes that the child is in need of assistance and that need has persisted for over one year. The trial court terminated her parental rights and this appeal resulted. The court of appeals reversed the trial court and the Iowa Supreme Court granted cert.
ISSUE: Is severe mental illness alone enough of a reason to terminate a mother child relationship?
RULE OF LAW: Yes. Severe mental illness alone is enough of a reason to terminate a mother child relationship.
HOLDING AND DECISION: The mother has a severe form of schizophrenia and is unable to recognize or have insight into the symptoms and to seek aid when necessary. She denies having the illness and despite its repeated return seeks freedom from her medication believing that her medication is the source rather than the cure. Her own doctor believes that her current cooperation in treatment is motivated solely by her desire to obtain custody; this despite the strong belief by the Dr. that mentally ill persons like the mother have a right not to have the legal ties to their children severed under any circumstances. As for the child it is not in her best interests to endure repeated proceedings and foster placements for the remaining years of her childhood. The child is suffering from considerable confusion, anxiety and a lack of trust; those who have examined her cite the need for long term placement. While there is no guarantee that termination will result in a permanent home it is the best hope for that result.
DISPOSITION: Reversed.