October 02, 2018 Feature

Review of the Year 2017 in Family Law: Case Digests

I. Adoption

Idaho. Doe I (2017–13) v. Doe II, 402 P.3d 1089 (Idaho 2017). Grandmother’s former girlfriend petitioned for co-adoption of two grandchildren and visitation based on the parties’ original petition for co-adoption, which was denied. The lower court granted grandmother’s motion to dismiss, and former girlfriend appealed. The supreme court held that the original petition for co-adoption of the grandchildren was insufficient to constitute written consent for the adoption, and it did not constitute irrevocable consent to co-adopt with grandmother’s former girlfriend.

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