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

Summary

The Alaska Supreme Court affirmed the termination of Chloe's parental rights to Ashanti. It held that appellate review of the active-efforts finding was limited to evidence presented at the remand hearing, that clear and convincing evidence supported OCS's active reunification efforts, and that expert testimony supported the finding that Ashanti would likely suffer serious harm if returned to Chloe. The court also declined to remand for an ineffective-assistance inquiry because the proposed claim was unlikely to succeed and further delay would undermine the statutory goal of permanency.