Idaho Department of Health & Welfare v. Doe

I. Nature of the Case

Jane Doe (“Doe”) appeals from the magistrate court’s judgment granting the Idaho Department of Health and Welfare’s (“IDHW”) petition to terminate her parental rights. Doe asserts that the magistrate court erred by: (1) terminating her parental rights notwithstanding its finding that her mental health issues made it impossible for her to comply with the case plan; and (2) considering evidence outside of the record during the termination trial.

II. Factual and Procedural Background

Doe has three children, Z.C. (born 2007); J.C. (born 2008), and D.C. (born 2012)…