Idaho Department of Health & Welfare Ex Rel. Doe v. Doe, 158 Idaho 764

John Doe has a long history of methamphetamine addiction, multiple criminal convictions, repeated periods of incarceration, and numerous failed or incomplete drug-treatment attempts spanning decades.
Daughter L.E. was removed by the Idaho Department of Health and Welfare (IDHW) in August 2012; IDHW obtained custody and implemented a case plan requiring substance-abuse treatment, testing, stable housing/employment, parenting classes, and ongoing contact.
Doe had intermittent compliance: completed some treatment and parenting classes, had periods of visitation and brief extended home visits, obtained housing and employment at points, but repeatedly relapsed, failed numerous UAs (positive tests, failures to report/produce), and had further arrests between 2013–2014.
L.E. was placed with Doe’s father/stepmother after home visits ceased; IDHW changed permanency plan to termination and adoption in 2014 and filed a termination petition on June 6, 2014.
The magistrate found by clear and convincing evidence that Doe neglected L.E. (both failure/inability to provide parental care and failure to comply with the case plan under the 15-of-22-months rule), and that termination was in L.E.’s best interest; the court terminated Doe’s parental rights. Doe appealed; the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether neglect occurred where Doe’s absences were not willful and he substantially complied with the case plan	Doe: absence not willful; substantial compliance; IDHW’s unreasonable efforts impeded progress	IDHW: evidence shows failure/inability to provide parental care and noncompliance with case plan	Court: Willfulness unnecessary; substantial competent evidence of neglect (incarceration, relapse, instability) supports termination
Whether reunification timing and best interest findings were erroneous because Doe proved sobriety and can reunify	Doe: now sober and improving; reunification possible soon	IDHW: child needs permanency given instability and long custody period; reunification not achieved within statutory timeline	Court: Court will not reweigh evidence; ample evidence supports best-interest finding and lack of timely reunification

Idaho Dep’t of Health & Welfare v. Doe, 154 Idaho 175, 296 P.3d 381 (2013) (standard of review and burden in termination appeals)
Idaho Dep’t of Health & Welfare v. Doe, 152 Idaho 263, 270 P.3d 1048 (2012) (willfulness not required for neglect finding)
Idaho Dep’t of Health & Welfare v. Doe, 151 Idaho 846, 264 P.3d 953 (2011) (incarceration as competent evidence of neglect)
In re Doe, 143 Idaho 343, 144 P.3d 597 (2006) (parental inability to comply with law relates to child well‑being)
In re Doe, 156 Idaho 103, 320 P.3d 1262 (2014) (appellate review will not reweigh evidence; substantial evidence standard)
Roberts v. Roberts, 138 Idaho 401, 64 P.3d 327 (2003) (findings need only be supported by substantial, possibly conflicting, evidence)
Huff v. Singleton, 143 Idaho 498, 148 P.3d 1244 (2006) (issues unsupported by authority or argument will not be considered)