Betsy F. v. State of Alaska, Dfcs, Ocs

Summary

The Alaska Supreme Court affirmed the superior court’s denial of a placement request for an Indian child, holding that the Indian Child Welfare Act’s active‑efforts requirement does not apply to extended‑family members such as the child’s great‑grandmother in a placement‑review context. The Court based its decision on a textual reading of 25 U.S.C. §1912(d) and related provisions, concluding that active efforts are limited to parties seeking foster‑care placement or termination of parental rights involving a parent or Indian custodian.