Ronald H. v. State of Alaska, Dhss, Ocs

Summary

The Alaska Supreme Court affirmed the termination of Ronald H.'s parental rights, holding that the Office of Children's Services made the active efforts required by the Indian Child Welfare Act. Although OCS could have done more, its overall efforts were sufficient in light of the services it provided and Ronald's repeated unwillingness, disruption, and hostility that impeded treatment and visitation. The court also held that OCS's inadequate initial investigation of alleged sexual abuse and its written communications with Ronald did not negate its otherwise active efforts. No separate opinions were filed.