When the Presumption Isn’t the Point: What Hines-Miller v. Teter Gets Right About Perpetrator Patterns

Family CourtPerpetrator BehaviorSystems Change
Written By Jessica Sisler

By Leah Vejzovic, LMSW; North America Regional Manager, Safe & Together Institute; Lifelong Resident of Iowa

Iowa’s Supreme Court just handed down a custody modification ruling that most family law practitioners will read as a case about statutory interpretation, and it is. But underneath the parsing of “custody” versus “physical care” in Iowa Code Chapter 598, Hines-Miller v. Teter (No. 24-1879, filed May 15, 2026) is something rarer: an appellate court reasoning almost entirely in pattern logic, even though it never once uses the words “coercive control.”

For those of us who spend our days trying to get courts, caseworkers, and case staffings to stop asking “Was this incident bad enough?” and start asking “What is this person’s pattern?”, this ruling is worth getting familiar with.

The Facts, Briefly

A father was awarded primary physical care of his son in 2020 despite a documented history of domestic abuse against the child’s mother: three separate incidents by trial, including strangulation. Two modification petitions followed. The first was denied because a new abuse conviction, this time against a girlfriend, was treated as “isolated.” The second, the case now before the Iowa Supreme Court, was prompted by a fourth domestic abuse conviction, this one involving strangulation of his now-wife in bed, with two young children present.

Twice, lower courts looked at escalating abuse across multiple relationships and found a reason to call it contained. The Supreme Court didn’t buy it a third time.

Pattern Over Incident, Finally Named as Law

Here’s what stuck out to me most: the Iowa Supreme Court built its reversal around a father’s behavior across 13 years and at least four relationships, not around any single event. The court traced the trajectory explicitly—from a high school incident, to “getting physical” in 2015, to headbutting in 2016, to stalking and assault in 2020, to strangulation in 2023—and called it what it is: escalation, not the repetition of isolated incidents.

This is the entire premise of the Perpetrator Pattern Mapping Tool made into appellate reasoning. Every incident-based system—and family court is often the most incident-based system of all—wants to ask whether this event was serious enough to change an outcome. The court instead asked what the full pattern across time and across victims actually shows about risk. That question can’t be answered by looking at any single case file. It requires looking at the person’s entire history of using coercive control against their intimate partners.

Rejecting the “Direct Harm” Standard

The lower court’s reasoning included a line that will sound familiar to anyone who has sat in a staffing where a father’s violence toward an adult partner gets waved off because “it’s between the parents”: the finding that there was no evidence of a “direct negative effect” on the child.

The Supreme Court rejected this outright, citing decades of research and its own child welfare precedent to affirm that children are harmed by exposure to domestic violence whether or not they are its direct target and whether or not they were in the room. This matters enormously for child welfare practice, where “the kids weren’t touched” still functions, informally, as a reason to minimize risk. In this case, the Court rejected that standard, finding it unsupported by the law and by the evidence.

Naming Minimization as a Risk Factor, Not a Credibility Footnote

The court did more than recount the history. It gave lower courts a way to assess future risk: how much time has passed, whether the person has acknowledged their role, and what they’ve done beyond court-mandated compliance, and then used the father’s continued denial of well-documented violence as evidence against him. His insistence that “we literally don’t argue” and that reports of strangulation were fabricated wasn’t treated as a private matter between two adults. It was treated as diagnostic of ongoing risk to adult and child survivor safety.

This is the piece that too often gets lost in case planning: completion of a batterer’s education class is not the same as accountability. A person can check every court-ordered box and still be actively minimizing, denying, and controlling. The court’s insistence on looking past compliance to actual acknowledgment is exactly the distinction we push practitioners to make every day.

Where the Ruling Still Falls Short

I don’t want to overstate this. The opinion is still built almost entirely around criminal convictions and physical incidents. There’s no real exploration of coercive control as a standalone pattern: the isolation, the repeated relocations, the possible use of the child and the litigation process itself as instruments of continued control. The court notes, almost in passing, that an earlier ruling found “each party has used the child as a pawn” and that the father moved the family through six different residences and three school districts in five years. An incident-based framework treats that as an area of instability. A coercive control–informed framework would ask whether that instability is itself part of the pattern: whether relocation, in this family, functioned as a tool.

The court also credits the mother’s stability without naming her advocacy for her son’s wellbeing and her efforts to get him into counseling over the father’s objection as what they are: protective parenting directly responding to the impact of abuse. It’s in the record; the opinion just doesn’t label it as such.

And there’s a moment worth flagging for anyone doing multidisciplinary or systems-level work: neither of the father’s wife’s parents, testifying at trial, knew that his 2023 conviction was his fourth for domestic abuse. That’s not incidental. Perpetrator patterns often depend on exactly this kind of information gap: the people closest to a new partner frequently don’t have the full history, because the pattern itself works to keep it that way.

Why This Ruling Matters Beyond Iowa

Appellate reasoning that centers escalation across relationships, rejects “no direct harm” as a defense, and treats minimization as an ongoing risk factor gives practitioners something concrete to point to, not just as good practice, but as legally sound reasoning a state’s highest court has now endorsed. For those of us doing training with judges, GALs, and child welfare systems, that’s not nothing.

The work now is pushing the analysis the rest of the way: from “history of domestic abuse as a significant factor” to a full pattern-based, coercive-control lens that also credits protective parenting for what it is. Iowa’s Supreme Court got most of the way there. The next case, or the next training, can move us even further along the path to becoming truly domestic abuse–informed.

Additional Resources

Jessica Sisler
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