E. A. v. State, Division of Family & Youth Services

OPINION

EASTAUGH, Justice.

I. INTRODUCTION

A mother appeals the termination of her parental rights to her Native child. We affirm the trial court's holding that the state made active, unsuccessful efforts to prevent this termination. Although the state failed to obtain an updated psychological evaluation of the mother following her child's allegation that she had abused him, an update would not likely have increased the mother's chances for reunification given her inability to maintain long-term sobriety and her resistance to receiving treatment. We also hold that substantial evidence supports…