In the Interest of C.F.-h., Minor Child, C.H., Father

I respectfully dissent and would affirm termination of the father’s parental rights. The court offers various tests for what “removed from the physical custody of the child’s parent[]” means as used in Iowa Code section 232.116(l)(e )(2) and section 232.116(l)(/')(3) (2015). Boiled down, those tests require that there be a “dynamic change of circumstance, not stasis.” I think the court’s “dynamic change” test was easily satisfied under the facts of this case.

Here the father was living with both the mother and C.F.-H. until the fall of 2012. At that time, following the latest report of…