ࡱ> ~} \bjbj̵ (~צצJ %@08K,w\D" h: CCCCCCCEDHChhCTC$TTT6CTCTTn =q?_nGT> ?CLC<D1>@HTH@q?Tq?#C U:   Whose Rights Count? Confronting Violations of the Indian Child Welfare Act By Terry Cross and Sarah Kastelic Abstract: This case explores the historical and ongoing need to keep American Indian/Alaska Native children protected in their families and communities whenever possible. Part I is a real life child custody scenario that involved the Leech Lake Band of Ojibwe. It illustrates the need for and provisions of the Indian Child Welfare Act of 1978 (ICWA). Part II provides a policy context for the scenario, summarizing the impetus for ICWA and key provisions, including: eligibility (when ICWA applies), tribal notification, tribal jurisdiction, and placement preferences. The case closes with steps to take if ICWA is not being properly followed in an eligible child custody case. Part I: Case Scenario Beth is the mother of Dennis Doe, who was born in the spring of 2008, in Utah. Beth is an enrolled member of the Leech Lake Band of Ojibwe, and her home is in Minneapolis, Minnesota. While Dennis was born in Utah, Beth had no personal connection to Utah. The circumstances that caused her to be in Utah during the time her son was born may sound unique, but her situation and the reasons that caused her to be in Utah happen far too often. During her pregnancy with Dennis she felt overwhelmed with the circumstances of her life and called a toll-free number from Minnesota that ultimately connected her to a private adoption agency in Utah. Beths choice was in part driven by a desire to avoid both county and tribal child welfare agencies. She was known to both for prior child protection issues, and she reportedly hoped to avoid the scrutiny of either, given her current situation. In the prior situation, the county had followed the federal Indian Child Welfare Act (ICWA) by notifying the tribe and followed the tribal-state agreement by partnering with the tribe on a case plan that had been successfully resolved. The tribe had intervened with the state court and exercised its authority under ICWA to become a full party in the court proceedings. In April, Beth and her older son, Joe, traveled to Utah through arrangements made by a private adoption agency. She was offered free transportation and coverage for all of her medical expenses. Beth made the adoption agency aware that she was an enrolled member of an Indian tribe. It is unknown whether she disclosed the prior child welfare contact or not or whether she requested or was offered anonymity. ICWA is unclear about the need for an adoption agency to notify a tribe prior to a voluntary adoption. It clearly requires notification after a voluntary adoption and sets specific guidelines that must be followed regarding how a voluntary consent is obtained, requiring that such consent cannot happen within 10 days of the birth and that it must be signed in front of a judge and be provided in the primary language of the parent. During the April visit, Beth first met the prospective adoptive parents. The adoption agency had matched the family with Beth. Prior to the match, Beth knew nothing about the family. The trip lasted only for a few days. Beth then returned to Minnesota. During the trip, Beth spent limited time with the adoptive family. Beth was unaware that ICWA creates an order of preference for placement of Indian children when they are to be adopted: first with a family member, then a member of the childs own tribe, and then with another Indian family. The prospective adoptive family met none of the criteria. Further, Beth was likely not aware that her child, upon birth, would have his own rights under ICWA. The U.S. Supreme Court had ruled in a Mississippi Choctaw case that an Indian parent did not have the right to deprive their child of their rights as citizens of a tribe. The interests of an Indian child include the right to: services and resources of their tribe, traditional cultural resources, own land, eventually vote, or hold office, among others. The adoption agency, experienced in ICWA, was likely aware of such issues but apparently chose to ignore them. When Beth was within days of her due date, she once again traveled to Utah through arrangements made by the adoption agency. Beth made this trip by airplane despite being approximately 38 weeks pregnant. Beth indicated she was asked to travel at 38 weeks to give some certainty that she would give birth in Utah. Once she arrived in Utah, she had a series of doctor appointments and was ultimately induced. Dennis was born at 7:26 p.m. that evening. There is documentation that Beth expressed anxiety about the prospect of placing him for adoption even prior to Dennis birth. Why she ultimately decided to sign the consent document may never be known. However, the circumstances surrounding the consent are disconcerting. In the evening hours, immediately following Dennis birth, Beth told hospital staff and representatives from the adoption agency that she could not go through with the adoption. The morning following the birth, the adoptive family was contacted by the agency and told that Beth was not going to place Dennis for adoption. The adoptive mother wrote in her blog as follows: The adoption agency director told me that she had talked to Beth and explained how things were going to work. She told her if she decided not to place the baby, the State of Utah would take him into custody because of the drugs in his system, and that they would then contact the State of Minnesota, and they would take her other children away. Beth told the director that Minnesota told her that if the baby didnt test positive for heroin that they wouldnt take her other kids. The director told her she really thought she was wrong. The following day, Beths son, Joe, was placed on an emergency hold in Minnesota. Interestingly, the State of Utah child protection agency was never contacted by the adoption agency or the hospital, both of whom would be mandatory reporters regarding a new born with drugs in their system. Had state child welfare services been notified, they would have had an obligation under ICWA to notify the childs tribe, and the case may have been handled differently from that point on. ICWA, however, has some gaps when a voluntary adoption is involved, and so the policies and procedures of the Utah State child welfare agency were never activated. Beth reported that the adoptive family and the director told her that if she would just sign the consent papers, everything would be okay. She recalls them telling her that by signing she was making the best choice. She also recalls being prayed over. Sometime during the evening of the day following the birth, the adoption agency secured the consent in clear violation of ICWAs consent provisions. The adoptive family reported that they were notified at 10:30 p.m. that the papers were signed. The agency has always claimed that the consent was signed 24 hours after Denniss birth, although there is no documentation of time on the consent. There were two witnesses to the consent, including the executive director of the agency. Beth described being physically and emotionally exhausted. She also believes she had been given medication for sleep and to relieve pain, and she was very tired. Her medical records from Utah have never been released to her, despite requests. Beth was flown back to Minnesota to attend the emergency placement hearing for her other children. Less than a week after Dennis was born and prior to him being released from the hospital, Beth revoked her consent in writing. The Leech Lake Child Welfare Department (LLCWD) petitioned the tribal court to assume jurisdiction over Dennis. This request was granted. An adoption petition was filed almost a month later in Utah District Court. The adoption petition was not granted. Beth had a history of involvement with county child protective services. She acknowledged struggling with chemical dependency and mental health issues. She had been evaluated for bi-polar disorder. At the time of the hearing in Minnesota, she was compliant with her medication; however, she reported that she was unable to take all of her medication during pregnancy. LLCWD had consistently been involved in child protection proceedings involving Beth and her children in Minnesota. Beth is an enrolled member, and the Leech Lake Band recognized all of her children as tribal members. Unequivocally, if Beth would have given birth to Dennis in Minnesota, his membership in the Leech Lake Band would have been recognized immediately. The crux of the adoptive familys argument was that they do not recognize Dennis as an Indian child. Unaware that only tribes can determine whether an individual is eligible for membership and thus is protected under ICWA, they petitioned the Utah courts to uphold the adoption based on their assessment that Dennis was not eligible for tribal membership, and thus not covered by the federal Indian Child Welfare Act (ICWA). They based this conclusion on their interpretation of what being Indian means, their analysis of blood quantum, and the advice of the adoption agency. They acknowledge knowing, even prior to Dennis birth, that Beth was an enrolled member of the Tribe. In addition to the ICWA issues, Dennis father, who is married to Beth, never consented to the adoption. The Leech Lake Band asserted its jurisdiction, and it was left to the Utah courts to decide whether to return Dennis to the Tribe. Despite pick-up orders, that should have been recognized in Utah under the full faith and credit provisions of ICWA, dating back to the month of the birth, Dennis was still not returned to Minnesota at the age of six months. The adoptive parents began to claim that he was now bonded to them and should not be moved. Their claim to the Utah courts included the position that they were good parents and returning Dennis to a family with chemical dependency and mental health challenges was inappropriate. The Tribes position was that the issue was under the jurisdiction of the tribal court and not the State of Utah, and it was the Tribes right to decide the future of their citizen. Their position was that Dennis would return to tribal foster care for protection. Each party had unique perspectives and each had rights or obligations under various jurisdictions. Resolution of this case required that the courts weigh the various rights and interests and ultimately resolve the disputed circumstance according to the law. Part II: The Policy Context Several key issues and relevant provisions of ICWA are highlighted by the case above: Eligibility, and who determines if ICWA applies Voluntary adoptions and protection from coercive practices Tribal notification Consent to relinquish for adoption The existence of a tribal court and the effect of tribal court orders Petition for return of jurisdiction The existence of tribal child welfare services The Indian Child Welfare Act is a federal law that seeks to keep American Indian/Alaska Native children with American Indian families. Congress passed ICWA in 1978 in response to the number of Indian children that were being removed from their homes by both public and private agencies. The intent of Congress under ICWA was to "protect the best interests of Indian children and to promote the stability and security of Indian tribes and families" (25 U.S.C. 1902). ICWA sets federal requirements that apply to state child custody proceedings involving an Indian child who is a member of, or eligible for membership in, a federally recognized tribe.  Historically, an alarmingly high percentage of Indian families, in comparison to the general population, have been broken up by the often unwarranted removal of their children by non-tribal public and private agencies. A disturbingly large proportion of such children have been placed in non-Indian foster and adoptive homes and institutions. A 1976 study by the Association on American Indian Affairs found that 2535% of all Indian children were being placed in out-of-home care. Eighty-five percent of those children were being placed in non-Indian homes or institutions (Unger, 1977). Indian children have a unique political status as members of sovereign tribal governments. Congress, through the Constitution, statutes, treaties, and the general course of its intergovernmental relationship with Indian tribes, is charged with the responsibility for the protection and preservation of Indian tribes and their resources, including Indian children. The special political status of Indian tribes, as well as the history of biased treatment of Indian children and families, under public and non-Indian private child welfare systems, is the basis for the enactment of ICWA (25 U.S.C. 1901). ICWA Context When ICWA applies to a childs case, the childs tribe and family will have an opportunity to be involved in decisions affecting services for the Indian child. A tribe or a parent can also petition to transfer jurisdiction of the case to their own tribal court. ICWA sets out federal requirements regarding removal and placement of Indian children in foster or adoptive homes and allows the childs tribe to intervene in the case. Indian children involved in state child custody proceedings are covered by ICWA. A person may define his or her identity as Indian, but in order for ICWA to apply, the involved child must be an Indian child as defined by the law. ICWA defines an "Indian child" as "any unmarried person who is under age eighteen and is either (a) a member of an Indian tribe or (b) is eligible for membership in an Indian tribe and is the biological child of a member of an Indian tribe" (25 U.S.C. 1903). Under federal law, individual tribes have the right to determine eligibility, membership, or both. However, in order for ICWA to apply, the child must be a member of or eligible for membership in a federally recognized tribe. ICWA does not apply to divorce proceedings, intra-family disputes, juvenile delinquency proceedings, or cases under tribal court jurisdiction. ICWA Eligibility All tribes have the right to determine who is a member of their tribe, and different tribes have different requirements for eligibility. In order to understand these requirements for the particular tribe in question, it is necessary to actually contact the tribe. The U.S Department of Interior, Bureau of Indian Affairs periodically publishes a formal list of designated tribal agents, which includes the contact information for each federally recognized tribe for the purposes of notifying a tribe of the removal of an Indian child which could potentially be a member of their tribe. If a child does not meet the definition of Indian child outlined in the Act, ICWA would not apply to the childs case. Other federal and state laws, however, may provide other protections, including relative placement provisions and the opportunity to be heard in a case review hearing. ICWA Compliance State caseworkers must make several considerations when handling an ICWA case, including: Providing active efforts to the family (described in detail below) Identifying a placement that fits under the ICWA preference provisions Notifying the childs tribe and the childs parents of the child custody proceeding Working actively to involve the childs tribe and the childs parents in the proceedings Caseworkers should be able to explain parental and tribal rights under ICWA and any other case actions in a manner that is easy for family members to understand. States are required to provide active efforts to families, and the court will be asked to determine whether active efforts have been made. The definition of "active efforts" is left open in the Indian Child Welfare Act to accommodate individual case decisions. However, federal guidelines do exist. ICWA mandates the state to make active efforts in every ICWA case in two areas, to: Provide services to the family to prevent removal of an Indian child from his or her parent or Indian custodian; and Reunify an Indian child with his or her parent or Indian custodian after removal. A cornerstone in the application of active efforts is active and early participation of the tribe, including consultation with the childs tribe regarding all case planning decisions. Additionally, active efforts is more intensive than "reasonable efforts." For example, reasonable efforts might be only a referral for services, but active efforts would be to arrange for the best-fitting services and help families engage in those services. The federal guidelines referenced above apply whether or not the childs tribe is involved in the custody proceedings. When it is necessary for an Indian child to be removed from a home, ICWA-mandated placement preferences include, in this order: (i) a member of the Indian child's extended family; (ii) a foster home licensed, approved, or specified by the Indian child's tribe; (iii) an Indian foster home licensed or approved by an authorized non-Indian licensing authority; or (iv) an institution for children approved by an Indian tribe or operated by an Indian organization which has a program suitable to meet the Indian child's needs (25 U.S.C. 1915). The law also allows for tribes to set a different order of preference by tribal resolution. If there is concern about whether ICWA is being applied correctly in a childs case, the following people should be contacted as soon as possible: An attorney (Indian law experience preferred) Legal services The childs tribe The state court may order different services or a different placement if it is determined that ICWA is not being applied correctly. Since 1978 there have been at least three attempts to amend the Indian Child Welfare Act. Each has failed, and so the law remains as written, despite its flaws. Placement rates of American Indian children have dropped dramatically but are still three times the national average. ICWA has had, in most ways, the impact that was intended, and where tribes assert their rights, ICWA tends to be working. In conclusion, ICWA recognizes the sovereignty of American Indian/Alaska Native tribal governments and the importance of Native children to the continued existence of Native communities and cultures. It provides important protections for Native children, encourages the preservation of Native families, and empowers tribal governments to exercise their sovereignty to act in the best interests of their children. References Bureau of Indian Affairs, U.S. Department of Interior. (1979, November 26). Guidelines for state courts; Indian child custody proceedings. Federal Register, Vol. 44, No. 228. Retrieved on 11/01/11 from  HYPERLINK "http://www.nicwa.org/policy/regulations/icwa/ICWA_guidelines.pdf" http://www.nicwa.org/policy/regulations/icwa/ICWA_guidelines.pdf Indian Child Welfare Act, P.L. 95-608, 25 U.S.C. 1901 (1978). Unger, S. (Ed.). (1977). The Destruction of American Indian Families. New York, New York: Association on American Indian Affairs.  Copyright (2011) held by AV. Please use appropriate attribution when using and quoting this case. Cases are available at the Native Cases website at http://nativecases.evergreen.edu/. This material is based upon work supported by the National Science Foundation under Grant No. 0817624. Any opinions, findings, and conclusions or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the National Science Foundation.  Terry Cross, an enrolled member of the Seneca Nation of Indians, is the developer, founder, and executive director of the National Indian Child Welfare Association.  Sarah Kastelic, an enrolled citizen of the Native Village of Ouzinkie, serves as the chief of staff for the National Indian Child Welfare Association.  Much of the material below was adapted from the website of the National Indian Child Welfare Association at  HYPERLINK "http://www.nicwa.org/Indian_Child_Welfare_Act/" http://www.nicwa.org/Indian_Child_Welfare_Act/.  For the full text of the law, please see  HYPERLINK "http://www.nicwa.org/Indian_Child_Welfare_Act/ICWA.pdf" http://www.nicwa.org/Indian_Child_Welfare_Act/ICWA.pdf.  For a detailed overview of the child welfare system, please see  HYPERLINK "http://www.childwelfare.gov/pubs/factsheets/cpswork.cfm" http://www.childwelfare.gov/pubs/factsheets/cpswork.cfm. For a familys guide to the child welfare system, please see  HYPERLINK "http://www.nicwa.org/Indian_Child_Welfare_Act/familyguide.pdf" http://www.nicwa.org/Indian_Child_Welfare_Act/familyguide.pdf.  For a flowchart of the Indian child welfare system and glossary of related terms, please see  HYPERLINK "http://www.nicwa.org/Indian_Child_Welfare_Act/glossary.pdf" http://www.nicwa.org/Indian_Child_Welfare_Act/glossary.pdf.  For more information on the history of the child welfare system and its treatment of Native children, see part II of the AV teaching case study A Case for Customary Adoption. Enduring Legacies: Native Cases http://nativecases.evergreen.edu/  See  HYPERLINK "http://www.bia.gov/idc/groups/xois/documents/document/idc014105.pdf" http://www.bia.gov/idc/groups/xois/documents/document/idc014105.pdf.  For a copy of the state court guidelines, please see  HYPERLINK "http://www.nicwa.org/administrative_regulations/icwa/ICWA_guidelines.pdf" http://www.nicwa.org/administrative_regulations/icwa/ICWA_guidelines.pdf.     PAGE  PAGE 1 -JKLM]^qrt}~   3 4 U t   I "evj*hy t!v!!! 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