R.B. v. C.W.

¶ 1 T.A.W. is an “Indian child” under the federal Indian Child Welfare Act of 1978 (ICWA), 25 U.S.C. §§ 1901-1963, as well as the Washington State Indian Child Welfare Act (WICWA), chapter 13.38 RCW. T.A.W.’s biological father, C.W., is non-Indian,1 and T.A.W.’s mother, C.B., is Indian and an enrolled member of the Shoalwater Bay Tribe.2 C.B. and T.A.W.’s stepfather, R.B.,3 successfully petitioned the trial court to terminate C.W.’s parental rights and to allow R.B. to adopt T.A.W. In reaching its decision, the trial court found that ICWA applied to the termination proceedings and that ICWA’s…