North Dakota Supreme Court

Interest of D.G. & D.G.

February 12, 20262026 ND 37

Summary

The Supreme Court held that a juvenile court must make a threshold determination of ICWA applicability for each new termination petition when the record does not show that the inquiry was made. Because the juvenile court made no finding regarding ICWA applicability, its findings were clearly erroneous and the termination judgments were remanded for further findings. No separate opinions were filed.