Philip J., Appellant v. State of Alaska, Department of Health & Social Services, Office of Children's Services…

Summary

The Alaska Supreme Court affirmed both orders terminating Philip J.'s parental rights to eight children. It held that OCS made active efforts under ICWA by considering its involvement over the entire case, including extensive referrals, assessments, transportation, visitation, and case planning, while accounting for Philip's repeated refusal to participate. It also held that sufficient evidence supported finding Alyssa was a child in need of aid based on the substantial risk from Philip's history of domestic violence and substance abuse.