H & W v. Jane Doe (2016-43), 44536

Trial to terminate Jane and John Doe’s parental rights began May 10, 2016, continued July 6–8, 2016; parties ordered to file closing arguments by August 12.
On October 3, 2016, the magistrate announced loss of written work due to software failure and orally pronounced detailed findings of fact and conclusions of law on the record, stating he would not reduce them to writing.
The magistrate entered a written judgment terminating parental rights that did not include specific written findings or conclusions beyond a general best‑interests statement.
Two days later the magistrate filed an “Amended Findings of Fact, Conclusions of Law, and Order” that (a) corrected a statutory citation, (b) incorporated the oral findings by reference, and (c) analyzed one termination ground more fully, concluding the Department failed to prove that ground; the order stated termination was based on Counts II and III.
Jane timely appealed separately, arguing the magistrate violated I.C. § 16‑2010(1) by failing to issue a written order reciting the findings of fact and conclusions of law required to terminate parental rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether I.C. § 16‑2010(1) requires written findings in the termination order	Jane: statute unambiguously requires every termination order be in writing and "recite" findings	Department: oral findings incorporated by reference (and court reporter transcript) suffice	Court: statute unambiguous; written recitation required and incorporation by reference or transcript does not comply
Whether the magistrate's amended order satisfied the statute by referencing oral findings	Jane: incorporation by reference insufficient to meet "recite" requirement	Department: incorporation by reference to oral pronouncement cures defect	Court: incorporation by reference is not the functional equivalent of written recitation; inadequate
Whether the amended judgment’s summary conclusion about best interests met statutory requirements	Jane: summary conclusion without supporting written facts is insufficient	Department: general statement that termination is in children’s best interests is adequate	Court: insufficient; judgment must recite findings supporting best‑interest conclusion
Remedy for statutory noncompliance	Jane: reversal/remand for compliance	Department: (implicit) allow existing records or transcript to stand	Court: remand for expedited preparation of written findings of fact and conclusions of law; appellate merits not addressed

Aguilar v. Coonrod, 151 Idaho 642, 262 P.3d 671 (statutory interpretation reviewed de novo)
Verska v. Saint Alphonsus Reg'l Med. Ctr., 151 Idaho 889, 265 P.3d 502 (statutes construed by plain meaning and as a whole)
State v. Owens, 158 Idaho 1, 343 P.3d 30 (defining required attributes of court orders)
Anstine v. Hawkins, 92 Idaho 561, 447 P.2d 677 (duty to follow unambiguous statutory language)