F-14 - Matter of Adoption of T.A.W. - A Case Study and Examination of Indian Child Welfare   Advanced

  Legal   Diversity

An Indian mother and her husband sought to terminate the non-Indian biological father’s parental rights to TAW, an Indian child, to allow the husband/step-father to adopt the child.  The Superior Court granted the petition and the biological father appealed. The Court of Appeals, reversed and remanded based on the mother’s failure to show that “active efforts” had been made to mitigate the father’s parenting deficiencies.  The mother and husband appealed to the Washington Supreme Court.