Adoption of HANNAH S.,
In assessing whether Indian child's mother had complied with requirement of Indian Child Welfare Act to show active efforts to prevent the breakup of an Indian family, court did not apply proper standard where it sought evidence beyond a reasonable doubt as opposed to clear and convincing evidence. Court erred in basing statement of decision denying mother's petition to terminate parental rights of child's Indian father solely on expert testimony rather than all the evidence before the court.
Comments on Adoption of HANNAH S.,