Adoption of Arnold

The appellant is a member of the Wampanoag tribe and the biological father of three children who are the subject of a parental rights termination proceeding brought pursuant to G. L. c. 210, § 3. His tribal affiliation implicated the Indian Child Welfare Act, 25 U.S.C. §§ 1901 et seq. (1994), in the State court termination proceeding. On appeal, the father asserts error in four respects: (1) the tribe did not receive timely notice of the proceedings in violation of 25 U.S.C. § 1912; (2) certain subsidiary findings of fact were clearly erroneous; (3) the trial judge erroneously admitted…