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

Summary

The court affirmed the termination of Josh L.'s parental rights, holding that OCS satisfied ICWA's active-efforts requirement despite deficiencies in visitation, family contact, and continuity of caseworker assignment. Because Josh was incarcerated for the duration of Eva's minority, OCS's efforts to reunify Eva with her available mother, facilitate communication, and investigate relatives were sufficient under the circumstances, and placement preferences generally were distinct from the termination inquiry. Justice Winfree, joined by Justice Stowers, dissented and would have reversed because OCS failed to investigate requested family placements as part of its active efforts.