Unpublished Illinois ICWA Case on Termination Standard

Here. Fairly long case to be unpublished, and odd reading for an ICWA case–separating out the language of “beyond a reasonable doubt” from the additional standard that “continued custody of the child by the parent . . . is likely to result in emotional or physical damage to the child.” Rather, the court held:

 The conduct by both parents shows the absence of concern, interest, and responsibility as to their children under both the clear-and-convincing and reasonable-doubt standards.