Linda H. v. Tyler R. (In Re Micah H.)

*840 INTRODUCTION

This is an adoption case we first visited *841 in In re Adoption of Micah H ., 1 where we concluded that the county court applied the wrong standard of proof in determining abandonment. We further concluded that the active efforts requirement of the Nebraska Indian Child Welfare Act (NICWA) 2 applied to cases involving the termination of parental rights over Indian children, even when the parent is not of Native American descent. We remanded the cause to the county court.

On remand, the county court, applying the correct standard of clear and convincing evidence, found that (1) the…