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

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that OCS was not required to obtain court order requiring parent to participate in mental health services to satisfy Indian Child Welfare Act’s active efforts requirement, see 25 U.S.C. § 1912(d) (2012)
• deciding claim on direct appeal despite mother’s request for remand to trial court for evidentiary hearing
• affirming active efforts finding despite \little success [with obtaining treatment] other than to have [the parent's] name added to months-long waiting lists for several programs\
• placing burden on parent alleging ineffective assistance of counsel to establish both deficient performance and prejudice
• affirming active efforts finding despite “little success [with obtaining treatment] other than to have [the parent’s] name added to months-long waiting lists for several programs”
• rejecting remand request because (1) it would contravene child in need of aid statutes’ emphasis on expeditious resolution and (2) parent’s proposed claim clearly had no merit under test for ineffective assistance of counsel

Source: CourtListener parenthetical corpus (CC0).