IDHW v. John Doe (2022-32)
Annotate this CaseJohn Doe sought custody of his daughter, Jane Doe, who was removed from the care of her mother in Idaho when a child protection action was initiated by the Idaho Department of Health and Welfare (“IDHW” or “the Department”). Jane Doe and her maternal half-brother were removed from the custody of their mother in December 2020 due to allegations of abusive conduct. Jane Doe had previously been removed from her mother’s custody in 2018 due to substance abuse issues. John Doe lived in Texas with his wife, who was Jane Doe’s stepmother, and their child, Jane Doe’s paternal half-sibling. At the time of the removal, John Doe was considered a “non-offending parent.” However, the initial “Adjudicatory/Disposition Report of Investigation” filed with the magistrate court noted that John Doe was listed on the Texas Public Sex Offender Website. The magistrate court exercised jurisdiction over Jane Doe in early 2021 and placed her in the Department’s legal custody. As part of the case plan for John Doe, the magistrate court ordered John Doe “to comply with and complete the approval with the [Interstate Compact on the Placement of Children (“ICPC”)] process with the state of Texas[,]” to assess the suitability of John Doe as a placement option for Jane Doe. The ICPC process ordered by the court included a home study and a placement determination. Texas denied IDHW’s multiple requests to conduct a home study on John Doe due to John Doe’s history, which included two prior sex offenses and a past child protection order, along with allegations of physical abuse, sexual abuse, negligent supervision, physical neglect, and medical neglect. Texas also noted that John Doe was a registered sex offender who had previously failed to register. As a result, John Doe never completed a home study. John Doe thereafter requested the Idaho magistrate court revise its case plan to strike the requirement he complete the ICPC process. This request was denied, and the issue before the Idaho Supreme Court in this matter centered on whether the ICPC even applied to John Doe as an out-of-state, non-custodial parent. The Supreme Court affirmed the magistrate court’s order modifying the case plan and held that by its plain language, the ICPC did not apply to an out-of-state, non-custodial parent.
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