ICWA also does not violate the Tenth Amendment’s anticommandeering doctrine. ICWA’s “active efforts” and “diligent search” requirements apply equally to state and private actors.

The COA affirms the case against Clifford Thomas but vacates Jasmine Gordon’s conviction and remands for a new trial due to the ineffective assistance of Gordon’s counsel.

The Court of Appeals published two cases this week in child welfare cases. The first In re Kanjia and the second in In re McCarrick/Lamoreaux.

The Court of Appeals has addressed the one-parent in the context of a plea taken from a nonparent adult, In re Slater/Wiemer, issued March 25, 2014 (Docket 317132).