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

Summary

The Alaska Supreme Court affirmed termination of the incarcerated father's parental rights to his three youngest children. It held that the State made active efforts under ICWA, considering its involvement with the family as a whole and the limitations imposed by the father's incarceration, and that the superior court did not clearly err in finding termination in the children's best interests. The court also held that ICWA placement preferences were not part of the state-law best-interests inquiry.