Mississippi Band of Choctaw Indians v. Holyfield

Summary

The Court held that the Indian Child Welfare Act requires a uniform federal definition of domicile and that minor children generally share the domicile of their parents. Because both parents were domiciled on the Choctaw Reservation, the twins were reservation-domiciled despite being born off the reservation and voluntarily placed for adoption, giving the tribal court exclusive jurisdiction and rendering the state adoption decree void. Justice Stevens, joined by the Chief Justice and Justice Kennedy, dissented, arguing that the parents' deliberate abandonment and invocation of state-court jurisdiction should have permitted the state proceeding.