Doe v. Doe, 150 Idaho 46

John Doe II and Jane Doe married in 2002; Son born in 2003; family lived in Oregon and Idaho during marriage.
Father enlisted in the U.S. Army; later stationed in North Carolina; intermittent contact with Son occurred before 2005.
Mother moved to Pocatello, Idaho with Son; divorce proceedings began; parenting plan awarded joint legal custody, Mother primary residence, Father unsupervised visitation and travel costs borne by Father.
Father deployed to Iraq (2007–2008); contact with Son diminished; Mother remarried Stepfather in 2008, Son began calling Stepfather “Dad.”
Mother and Stepfather petitioned to terminate Father’s rights alleging abandonment; after trial, magistrate court terminated rights on abandonment/least-restrictive grounds and best interests.
Idaho Supreme Court reversed, finding the magistrate court failed to adequately consider evidence of just cause and Father’s financial/physical inability to maintain contact; no statutory abandonment established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is substantial evidence to terminate for abandonment	Doe argues Father willfully failed to maintain a normal relationship.	Doe contends just cause due to military duties and finances prevented contact.	No substantial evidence; reversal of termination.

In re Adoption of Doe, 143 Idaho 188 (Idaho 2006) (defines 'normal parental relationship' and just cause; requires considering financial/logistical factors)
In re Aragon, 120 Idaho 606 (Idaho 1991) (standard of review for termination decisions)
Santosky v. Kramer, 455 U.S. 745 (U.S. Supreme Court, 1982) (clear and convincing evidence standard for termination of parental rights)
State v. Doe, 143 Idaho 343 (Idaho 2006) (defines substantial, competent evidence and independent appellate review)
In re Matthews, 97 Idaho 99 (Idaho 1975) (considers hostility and visitation context as just cause for limited contact)