I did not realize how far behind I was on these. Here is a case from the end of June on active efforts from the Colorado Supreme Court.
To be honest, this case holding is one that most, if not all, states have come to agreement on either in case law, state law, or state policy.
The court concludes that ICWA’s “active efforts” is a heightened standard requiring a greater degree of engagement by agencies like DHS with Native American families compared to the traditional “reasonable efforts” standard.
Turtle Talk 
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