A smell, a noise, a photo — that's all it takes to make Peter Jackson's world crumble.
The details of the day his daughter Darcey-Helen Conley, 2, and her sister Chloe-Ann Conley, 1, were left to die inside a car by their ice-addicted mother three and a half years ago still haunt him.
"You feel like you're being suffocated," he says.
"You just want to lay in bed, pull the doona over your head, and be done with the day."
Earlier this year, the girls' mother, Kerri-Ann Conley, was convicted of their manslaughter, with the sentencing judge labelling her actions "grossly negligent".
Mr Jackson says if Conley had not decided to leave the children in the car, they would still be here.
However, he says the Queensland government's child protection system is also to blame.
"If the department of Child Safety had done what they were supposed to, then the girls would also still be here," he says.
"They both failed Darcey and Chloe."
While Conley serves her prison sentence, Mr Jackson is pursuing legal action, seeking damages for personal injuries he says stem from their deaths.
Late last year, the Supreme Court ruled he could proceed with a claim against the Department of Children as well as Conley and RACQ Insurance beyond the standard time limitation period.
A notice of claim – filed as part of that application – states he has sustained nervous shock, severe post-traumatic stress disorder, and severe anxiety as a result of the children's deaths, and was admitted to hospital in January 2020.
According to the documents, he received a phone call from Conley on November 23, 2019, saying she had left the children in the car and they were not breathing.
He told her to call an ambulance, then drove to her house.
When he arrived, he found Conley standing in the bath tub with the shower running and the children lying on the floor.
He says he then began performing CPR on Darcey, while Conley attempted the same with Chloe.
The girls were pronounced dead at the scene by paramedics.
Mr Jackson says he has horrific memories of his daughter Darcey and her sister Chloe in the bathroom that day, images he cannot escape.
"I relive that bathroom every night, every day."
He says every day since their deaths "has been a living nightmare".
"It's changed everything," he says.
"It's not just me that this has affected, it's the whole family. We've basically had to learn how to live again."
But he says what he learnt since the girls' deaths about how child safety handled the case, has strengthened his resolve to pursue legal action.
In February, an ABC Background Briefing investigation revealed a series of failures by Queensland's Child Safety department in the lead up to Darcey and Chloe's deaths.
In the weeks before the sisters died, a doctor reported concerns to the department that Darcey had been exposed to methamphetamines at her mother's house.
Mr Jackson had also reported that Conley had told him she'd fallen asleep on the couch, leaving Chloe in the car.
The Queensland Family and Child Commission report found "clear red flags" were overlooked, the system "should have done more" to promote their safety, and there was a lack of information-sharing across agencies.
Mr Jackson's notice of claim accuses the state of failing in its duty of care owed to Chloe and Darcey, and failing to intervene in circumstances where they should have known the girls would be exposed to significant risk.
"Child Safety knew their mother used ice," Mr Jackson told the ABC.
"They knew she drove around high, with Darcey in the car … that she refused to do drug tests.
"They knew she wanted to swap Chloe for an iPhone 7 [prior to her birth]."
In mid-2018, after Conley withdrew her consent, Child Safety closed the Intervention with Parental Agreement case, even though Conley had not completed or complied with case goals and there were ongoing disclosures from friends and family about her substance misuse.
Ahead of that decision, Queensland police were aware of reports Conley was using and allegedly dealing drugs from her home, but didn't share this information when requested by Child Safety.
Mr Jackson has been given leave to commence proceedings against the State of Queensland within 60 days of a conference, or agreement.
He has also been granted leave to sue Conley and her motor vehicle insurer — RACQ Insurance.
Lawyers for the insurance company have denied its client is obliged to indemnify Conley in respect of the claim for damages.
'A terrible situation'
An RACQ spokeswoman says the case is "rare and complex" as it concerns RACQ Insurance and the interpretation of CTP insurance legislation.
"Given the complexities, it's appropriate for the matter to now be going through the legal process, which RACQ is supporting. As this is now a legal matter, we cannot comment any further," RACQ said.
"We acknowledge this is a terrible situation, and our thoughts are with all those involved."
A spokeswoman for the Department of Children says they are committed to ensuring the state's child protection system "is as robust as possible".
"The Queensland Family and Child Commission undertook a child safety systems review following the deaths of Chloe and Darcey and made three recommendations. All three were accepted and have been implemented," she says.
"Queenslanders need to have confidence that vulnerable children can and will be looked after, and that there are systems in place to look after children who are at risk.
"We will always act as a model litigant in the conduct of all litigation, ensuring we meet our obligations to uphold ethical and professional standards, and deal with claims promptly."
Meanwhile, Mr Jackson continues to urge wider change to Child Safety.
"If we want real change, and if Darcey and Chloe's death are not to be in vain, child safety needs to be accountable," he says.
"An independent commission of inquiry must investigate the ongoing failings of the department and an independent supervisor must be appointed to oversee reform implementation."
