Demetria H. v. State, Dept. of Health & Social Services, Office of Children's Services

CARNEY, Justice.

I. INTRODUCTION

A mother appeals the termination of her parental rights to her son, an Indian child. She argues the trial court violated the Indian Child Welfare Act (ICWA) 1 by finding that the Office of Children's Services (OCS) made active efforts and that her continued custody of her son was likely to result in serious emotional or physical damage to him. She also argues that the trial court's latter finding was not supported by the testimony of a qualified expert as required by ICWA. We affirm the trial court's order terminating her parental rights because its findings…