Here.
Based on these authorities, we are persuaded that the
heightened standard of “clear and convincing” evidence should apply when Arizona courts decide whether good cause exists to deviate from ICWA foster or adoptive placement preferences. Because it is unclear what standard of proof the juvenile court applied here, we remand the good cause determination for reconsideration. Although we need not reach some of the parties’ remaining arguments, we address certain issues likely to recur on remand.
The authorities cited are 2015 Guidelines and case law from across the states.