Chloe W. v. State, Dept. of Health & Social Services, Office of Children's Services

Summary

The Alaska Supreme Court affirmed the termination of Chloe W.'s parental rights to her Indian child. It held that the trial court properly considered a post-trial stipulation, that Chloe failed to remedy the substance-abuse and mental-health conditions placing her child at risk, that OCS made active reunification efforts, and that continued custody by Chloe likely would cause serious harm and was not in the child's best interests. The court also held that Chloe's ineffective-assistance claim failed because she could not show that different representation would have changed the outcome.