Josh L., Appellant v. State of Alaska, Department of Health & Social Services, Office of Childre — Winfree, J…

Summary

Justice Winfree, joined by Justice Stowers, dissented from the decision affirming termination of Josh L.'s parental rights. The dissent would have held that the Office of Children's Services failed to make active efforts under the Indian Child Welfare Act because it did not meaningfully investigate or assist with placement of Eva with Josh's relatives, which could have enabled Josh to satisfy the adequate-arrangements requirement. The dissent would have reversed and remanded for further placement efforts.