Pravat P. v. State of Alaska, Department of Health & Social Services, Office of Children's Services

Summary

The Alaska Supreme Court affirmed the termination of a Laotian father's parental rights to his three sons, who qualify as Indian children under the Indian Child Welfare Act. The court held that OCS's reunification efforts—hearing aids, interpreters, culturally tailored outreach through a Buddhist temple, visitation with coaching, and parenting and emotion-management classes—crossed the threshold from passive to active efforts despite delays and imperfections, and that the father's persistent lack of cooperation excused minor faults in those efforts. It further upheld the findings that he failed to remedy the domestic violence and neglect that placed the children at risk, that returning the children to him would likely cause serious emotional or physical damage, and that termination served the children's need for permanency and best interests.