Health & Welfare v. Jane Doe (2016-47)

Jane Doe (“Doe”) appealed the magistrate court’s judgment granting the Idaho Department of Health and Welfare’s (“IDHW”) petition to terminate her parental rights. Doe claimed that the magistrate court erred by: (1) terminating her parental rights notwithstanding its finding that her mental health issues made it impossible for her to comply with the case plan; and (2) considering evidence outside of the record during the termination trial. Five permanency hearings were held between January 6, 2015 and December 15, 2015. Prior to the first permanency hearing, the Guardian ad litem again reported that while the Children were progressing, Doe was failing to comply with her case plan. Accordingly, it again recommended that the magistrate court move forward with the termination of Doe’s parental rights. IDHW’s report was substantially similar to its previous report; that is, Doe had continued her noncompliance with the case plan. Finding no reversible error in the magistrate court's judgment, the Idaho Supreme Court affirmed termination. View "Health & Welfare v. Jane Doe (2016-47)" on Justia Law