John Doe I v. John Doe II

Summary

The Idaho Supreme Court vacated an order terminating a biological father’s parental rights and a related decree of adoption. The court held that the magistrate court’s oral findings, which did not establish willful abandonment, conflicted with its later written decision finding abandonment, requiring remand for new findings of fact and conclusions of law.

Holdings

1. The court declined to reach the challenge to John Doe I's standing under the in-loco-parentis provision because John Doe II failed to challenge the magistrate court's alternative determination that John Doe I possessed a legitimate interest in the matter.
2. The termination order and adoption decree had to be vacated because the magistrate court's oral findings contradicted its written decision regarding whether John Doe II's failure to maintain a parental relationship was willful.

Questions Presented

1. Whether John Doe I had standing to petition for termination of John Doe II's parental rights.
2. Whether the magistrate court's findings supported termination of parental rights by clear and convincing evidence.
3. Whether the inconsistency between the magistrate court's oral findings and written conclusions required vacatur of the termination order and adoption decree.

Disposition

vacated