South Dakota SCT Issues ICWA Active Efforts Decision

Matthew L.M. Fletcher

Here is the opinion in In re S.H.E.

An excerpt:

The record demonstrates that DSS actively attempted to reunify the family. The services provided to Father, in conjunction with DSS’s considerable efforts to help Mother1 and Mother2, satisfy the “active efforts” requirement under ICWA. Accordingly, the circuit court did not err in finding, beyond a reasonable doubt, that reasonable and active efforts were made to reunify the family.