R.B. v. C.W.

¶1 CW1 is the biological father and CB is the biological mother of TAW, an Indian2 child. CB is an Indian, but CW is not. CW appeals the trial court’s order terminating his parental rights and allowing RB, CB’s husband, to adopt TAW. CW argues that the trial court erred because it did not comply with applicable provisions in the federal and state versions of the Indian Child Welfare Act (ICWA). Specifically, he argues that 25 U.S.C. § 1912(d) and RCW 13.38.130(1) required CB and RB to show that active efforts were made to provide CW with remedial services and rehabilitative programs to…