John Doe & Jane Doe (2017-19) v. John Doe I & Jane Doe I, 45180

Background

Child (born 2006) lived with maternal/paternal Grandparents off and on beginning around age 1; Parents had financial instability and periods of incarceration.
In July–August 2013 Child began living primarily with Grandparents; by August 2014 Child refused to return to Parents after alleged physical abuse by Father; a one-year protection order against Father was later granted.
Grandparents obtained temporary guardianship (March 2015) and arranged supervised sibling visits; visits ceased after eight sessions and no further consistent contact between Parents and Child occurred.
Between late 2014 and the 2017 petition, Parents provided no financial support for Child and had no direct contact with Child or Grandparents for over a year (phone records showed limited calls).
Grandparents petitioned to terminate Parents’ rights and to adopt Child; the magistrate found abandonment (failure to support and maintain contact) and that termination was in Child’s best interest, and entered final judgment; the Idaho Supreme Court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Parents abandoned Child under I.C. § 16-2005	Grandparents: Parents willfully failed to provide reasonable support and to maintain regular personal contact (prima facie abandonment).	Parents: They had limited means, significant responsibilities to other children, and made some contact attempts (calls/texts)—so no willful abandonment.	Affirmed: clear and convincing evidence of abandonment based on failure to support; court need not reach contact issue.
Whether termination is in Child’s best interest	Grandparents: Child improved physically, emotionally, and academically in their care; adoption by Grandparents would provide stability.	Parents: Dispute characterization of harm; note no criminal convictions or charges and contend siblings prospered under Parents.	Affirmed: substantial evidence Child’s wellbeing and stability supported termination.
Whether phone-call/contact evidence negates "without just cause"	Grandparents: Limited, sporadic calls do not amount to maintaining a normal parental relationship.	Parents: Ten calls and texts (some corroborated) show efforts to reconnect and possibly just cause for lack of contact.	Magistrate credited that few calls over nearly two years were insufficient; Supreme Court deferred to magistrate’s credibility findings.
Whether Grandparents are entitled to attorneys’ fees on appeal	Grandparents requested fees.	Parents did not seek fees.	Denied: request mentioned only in passing and unsupported by cogent argument, so court did not consider it.

Key Cases Cited

Idaho Dep’t of Health & Welfare v. Doe, 160 Idaho 824, 379 P.3d 1094 (2016) (standards for termination review and best-interest considerations)
Idaho Dep’t of Health & Welfare v. Doe, 158 Idaho 764, 351 P.3d 1222 (2015) (clear-and-convincing standard and appellate review principles)
Doe I v. Doe II, 150 Idaho 46, 244 P.3d 190 (2010) (consideration of logistical/financial difficulties and hostile relationships in abandonment analysis)
In re Doe, 156 Idaho 532, 328 P.3d 512 (2014) (factors in abandonment and parental capability)
Doe I v. Doe II, 148 Idaho 713, 228 P.3d 980 (2010) (willfulness requires capacity to act)
Doe v. Doe I, 149 Idaho 392, 234 P.3d 716 (2010) (lack of meaningful effort to maintain relationship supports abandonment)
In re Doe, 155 Idaho 505, 314 P.3d 187 (2013) (financial capability and abandonment analysis)
Doe I v. Doe II, 161 Idaho 532, 387 P.3d 785 (2016) (failure to provide reasonable support can alone establish abandonment)
In re Doe, 159 Idaho 192, 358 P.3d 77 (2015) (best-interest factors)
In re Doe, 157 Idaho 765, 339 P.3d 1169 (2014) (best-interest factors)
Bach v. Bagley, 148 Idaho 784, 229 P.3d 1146 (2010) (issues not argued with cogent authority will not be considered)
Inama v. Boise Cnty. Bd. of Comm’rs, 138 Idaho 324, 63 P.3d 450 (2003) (same)