This question was debated often in my ICWA class this year–what would active efforts consist of for a sex offender and/or pedophile parent (father, in this case)? The California Court of Appeals, 4th district, held there are none required:
Nevertheless, his history clearly demonstrates the futility of offering reunification services: He is a registered sex offender with a prior conviction for lewd and lascivious acts on a child under the age of 14. . . . The parents do not suggest any services which might have been offered to the father under the circumstances and we cannot conceive of any services which could usefully be offered to a registered sex offender with a prior conviction for molesting a child and a current finding of molesting a different child. For these reasons, requiring the court to provide services to the father would be at best an idle act which would not further the legislative purposes of ICWA.
While this quote is from the section of the case discussing active efforts prior to removal to foster care, the court came to the same conclusion for active efforts prior to termination.
Oddly, the court is also confused as to whether the father is Cherokee or Choctaw, using them interchangeably at one point.
Turtle Talk 