In Re Nicole B.

dissenting, joined by BELL, C.J.:

I respectfully dissent. I agree with the well-reasoned opinion of the Court of Special Appeals, Judge Sally Adkins writing for the majority, in which the court held that “the ‘active efforts’ standard [of the ICWA] requires more effort than a ‘reasonable efforts’ standard does [under § 5-525 of the Family Law Article of the Maryland Code].” In re Nicole B., 175 Md.App. 450, 472, 927 A.2d 1194, 1206 (2007).

I disagree with the majority’s decision to avoid answering the certiorari question1 in this case, i.e., whether “reasonable efforts” as used in the Federal…