context: Furthermore, even if admission of the evidence was error, it was harmless. Our de novo review shows us without this evidence the juvenile court had more than enough proof to support its decision.
citation_a.signal: see also
citation_a.identifier: 461 N.W.2d 478, 480-81
citation_a.parenthetical: evidence of parent's past actions which formed basis of prior CINA proceedings may be considered in new CINA proceeding as long as there is other clear and convincing evidence as basis of new CINA proceeding
citation_a.sentence: See, e.g., In re T.C., 492 N.W.2d 425, 429-30 (Iowa 1992) (in termination proceeding, admission of evidence of father’s juvenile criminal record was error, but the error was harmless); see also In re N.M.W., 461 N.W.2d 478, 480-81 (Iowa App.1990) (evidence of parent’s past actions which formed basis of prior CINA proceedings may be considered in new CINA proceeding as long as there is other clear and convincing evidence as basis of new CINA proceeding).
citation_b.signal: see
citation_b.identifier: 492 N.W.2d 425, 429-30
citation_b.parenthetical: in termination proceeding, admission of evidence of father's juvenile criminal record was error, but the error was harmless
citation_b.sentence: See, e.g., In re T.C., 492 N.W.2d 425, 429-30 (Iowa 1992) (in termination proceeding, admission of evidence of father’s juvenile criminal record was error, but the error was harmless); see also In re N.M.W., 461 N.W.2d 478, 480-81 (Iowa App.1990) (evidence of parent’s past actions which formed basis of prior CINA proceedings may be considered in new CINA proceeding as long as there is other clear and convincing evidence as basis of new CINA proceeding).