Idaho Department of Health & Welfare v. Jane Doe (2015-21)
Annotate this CaseA magistrate court terminated Appellant Jane Doe’s (“Mother”) parental rights to her nine-year-old child (“Child”) for neglect. Mother argued on appeal of that termination: (1) the magistrate court’s finding of neglect is not supported by clear and convincing evidence; (2) the magistrate court should have rejected the Idaho Department of Health and Welfare’s (“IDHW”) petition to terminate parental rights because IDHW had failed to make reasonable efforts to reunify Mother and Child; (3) the magistrate court abused its discretion when it took judicial notice of findings from a prior proceeding; and (4) the magistrate court abused its discretion when it admitted evidence of IDHW’s efforts to determine whether the Indian Child Welfare Act applied to Child. Finding no reversible error, the Supreme Court affirmed.
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