Jane Doe v. John Doe (In re Jane Doe II), 443 P.3d 213

IW (child) lived with maternal grandparents (Guardians) from infancy after parents left her; Guardians obtained California guardianship over Father's objection.
Father was later convicted of a lewd act on a child (MW, IW's half-sister), imprisoned, and released on parole when IW was three; Father has a history of mental illness and is a registered sex offender for the offense against MW.
Guardians moved IW from California to Idaho without prior California-court permission required by the guardianship order; the guardianship was later registered and terminated in Idaho.
Father made no meaningful financial support payments or sustained contact with IW after release; he spent some proceeds from selling his home and hired private investigators to locate IW but did not contact child support services or the Social Security Administration to arrange support.
Guardians petitioned in Idaho to adopt IW and terminate Father’s parental rights; the magistrate court found (1) statutory abandonment and (2) termination was in IW’s best interests; the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Father willfully abandoned IW (statutory abandonment)	Guardians: Father willfully failed to maintain a normal parental relationship (no support or regular contact) for the statutory period	Father: Lack of contact/support was not willful; there were justifications (incarceration, mobility, limited means)	Affirmed—substantial competent evidence that Father willfully failed to provide reasonable support and thus abandoned IW without just cause
Whether termination of Father's parental rights is in IW's best interests	Guardians: IW has stability, bonding, and permanency with Guardians; Father lacks stable housing, is on parole, and is a registered sex offender	Father: Implied argument that termination is unnecessary given subjective love and limited efforts to locate; best-interests factors weigh against severing parental rights	Affirmed—objective factors (stability, bonding, parental unfitness, lack of support) show termination serves IW's best interests

In re Doe, 157 Idaho 920 (discussing statutory termination requirements)
Dep’t of Health & Welfare v. Doe, 149 Idaho 207 (defining clear-and-convincing standard for termination)
In re Adoption of Doe, 143 Idaho 188 (explaining abandonment and burden to show just cause)
Doe v. Doe (In re Doe), 150 Idaho 46 (appellate standard — substantial competent evidence review)
Doe I v. Doe II (In re Doe), 148 Idaho 713 (willfulness requires capability to maintain relationship)
In re Aragon, 120 Idaho 606 (best-interests analysis for termination)