In re Z.K.
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The Supreme Court affirmed the ruling of the juvenile court that the Indian Child Welfare Act (ICWA) did not apply to the termination of parental rights proceedings below, holding that the juvenile court did not err in determining that Z.K. was not an "Indian child" under ICWA.
After holding a hearing on the applicability of ICWA the juvenile court concluded that ICWA remained inapplicable to Z.K. Turning to the merits, the juvenile court found that the State's reasonable efforts to avoid the out-of-home placement had been unsuccessful and proceeded to terminate the parents' parental rights to Z.K. The court of appeals affirmed. The Supreme Court affirmed, holding that the juvenile court properly determined that Z.K. did not meet the definition of "Indian child" under the applicable ICWA statutes.