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

Summary

The Alaska Supreme Court affirmed the adjudication of Jane as a child in need of aid. It held that Kyle waived his as-applied constitutional challenge by failing to raise it in the superior court and failing to establish plain error, and it concluded that the State made the active efforts required to address Jane's runaway behavior, substance abuse, and mental-health problems. The court emphasized that the active-efforts inquiry considers the State's efforts as a whole and may properly focus on the child's needs when those needs caused the adjudication.