Tara U., Appellant v. State of Alaska, Department of Health & Social Services, Office of Children's Services, Appellee

Summary

The Alaska Supreme Court vacated the termination order insofar as it rested on the superior court's reasonable-efforts finding and remanded for reconsideration under the totality of the circumstances. The court held that reasonable efforts must be evaluated using OCS's entire history of services, including efforts before and after removal, and that the superior court's inconsistent alternative findings prevented effective appellate review. The court otherwise upheld the finding that termination was in the children's best interests. Justice Fabe, dissenting, would have affirmed because Tara's refusal to cooperate supported the superior court's conclusion that post-removal efforts were reasonable.