Idhw v. John Doe

Summary

The Idaho Supreme Court affirmed the magistrate court’s order temporarily placing five children in the Department’s legal custody after a redisposition hearing. The court held that the magistrate court’s verbal findings were supported by substantial and competent evidence, and that its inadequate written findings were harmless because the hearing transcript permitted meaningful appellate review. The court also held that temporary removal under the Child Protective Act did not violate the father’s parental rights because the applicable standard was preponderance of the evidence, not strict scrutiny or clear and convincing evidence.