Chloe v. State, Department of Health & Social Services, Office of Children's Services

OPINION

FABE, Chief Justice.

I. INTRODUCTION

Chloe W.1 appeals the termination of parental rights to her three-year-old son Timothy, an "Indian child"2 under the Indian Child Welfare Act of 1978 (ICWA). She claims the trial court erred by: (1) relying too heavily on a stipulation filed after the close of evidence, which Chloe contends was the result of ineffective assistance of counsel; (2) finding that Chloe had not remedied the conduct that placed Timothy at risk; (8) finding that OCS made active efforts to reunify the family; and (4) finding that terminating Chloe's parental rights was in…