Idaho Department of Health & Welfare v. Doe, 244 P.3d 232

Jane Doe is a minor in Idaho under protective supervision due to CPA petition; Mother and Father stipulated to Department custody; John Doe is the unmarried biological father but not a parent under Idaho statute; paternity not established prior to termination; paternity testing later showed John Doe is Jane's biological father; John Doe never pursued paternity, custody, or support for four years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether John Doe qualifies as a legal parent under I.C. §16-2002	Doe never pursued parent status.	Doe argues he should have rights once biological link is shown.	Doe not a parent under statute; no parental rights.
Whether consent requirements under I.C. §16-1504 apply to John Doe	Consent required if he is an eligible biological father.	Doe did not meet conditions; he never filed acknowledgment or established relationship.	Consent not satisfied; no rights under adoption conservatorship.
Whether due process protected John Doe after termination proceedings commenced	Doe proffers due process requires opportunity to establish paternity upon notice.	Doe failed to grasp opportunity; due process not violated given lack of substantial relationship.	Due process not violated; opportunity to establish rights not pursued.

Doe v. Roe, 142 Idaho 202 (Idaho 2005) (standard for reviewing termination of parental rights; private rights must arise to be protected)
In re Julia U., 64 Cal. App. 4th 532 (Cal. App. 1998) (unwed father’s due process protection when promptly comes forward)
In re Steve B.D., 112 Idaho 22 (Idaho 1986) (cited for due process related principles in parental rights)
Lehr v. Robertson, 463 U.S. 248 (U.S. 1983) (due process limits on paternal rights when opportunity to connect with child is not pursued)
Caban v. Mohammed, 441 U.S. 380 (U.S. 1979) (due process related to parental rights and unwed fathers)