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

APPEL, Justice.

In this case, we are asked to consider when a child has been “removed from the physical care” of parents for at least twelve of the last eighteen months, thereby establishing a necessary element for termination of parental rights under Iowa Code section 232.116(l)(e) and (f) (2016). According to the parties on appeal, the father at no time had actual physical custody of the child. Nonetheless, the district *202court determined that for purposes of the statute, the child should be considered “removed” from the father’s physical care for the requisite time period to support a…