In Re Roberts

How courts have described this case

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

• applying dual burden of proof, requiring proof “beyond a reasonable doubt” that continuation of custody would cause child harm, but only “clear and convincing evidence” of the state termination grounds
• proof beyond reasonable doubt that parent’s custody likely to result in Indian child’s emotional or physical damage in addition to state parental termination requirements
• no abuse of discretion where witness had attended numerous workshops on Indian child welfare and was a committee member for two organizations involved in drafting ICWA

Source: CourtListener parenthetical corpus (CC0).

Cited by

16 cases in this archive cite this case.

• In Re AW
  Court of Appeals of Washington· 1988-12-19· cited 143×
• Department of Social & Health Services v. Johnson
  Court of Appeals of Washington· 1988-12-19· cited 67×
• Mahaney v. Mahaney
  Washington Supreme Court· 2002-07-25· cited 60×
• Valerie M. v. Arizona Department of Economic Security
  Arizona Supreme Court· 2009-01-12· cited 58×
• In Re the Appeal in Maricopa County Juvenile Action No. JS-8287
  Court of Appeals of Arizona· 1991-12-06· cited 57×
• In re the Welfare of L.N.B.-L.
  Court of Appeals of Washington· 2010-08-03· cited 50×
• Matter of NL
  Supreme Court of Oklahoma· 1988-04-19· cited 34×
• Carney v. Moore
  Supreme Court of Oklahoma· 1988-04-19· cited 28×
• Department of Social & Health Services v. Osborne-Tanner
  Court of Appeals of Washington· 1990-10-29· cited 12×
• Valerie M. v. Arizona Department of Economic Security
  Court of Appeals of Arizona· 2008-10-28· cited 11×
• In Re Welfare of LNB-L.
  Court of Appeals of Washington· 2010-08-03· cited 4×
• In Re Mahaney
  Washington Supreme Court· 2002-07-25· cited 4×
• Valerie M. v. ades/kaydee v. randy v. zachary V.
  Arizona Supreme Court· 2009-01-12
• In Re Welfare of Lnb-L
  Court of Appeals of Washington· 2010-06-29
• In Re Mf
  Supreme Court of Kansas· 2010-02-05
• S. H. v. Department of Children and Families and Guardian Ad Litem
  District Court of Appeal of Florida· 2026-01-09

Cites

10 cases in this archive are cited by this case.

• In Re Welfare of Sego
  Washington Supreme Court· 1973-08-30· cited 470×
• In Re the Welfare of Aschauer
  Washington Supreme Court· 1980-05-29· cited 189×
• Davis v. Department of Labor & Industries
  Washington Supreme Court· 1980-08-07· cited 164×
• In Re the Welfare of Young
  Court of Appeals of Washington· 1979-10-04· cited 31×
• Todd v. Superior Court
  Washington Supreme Court· 1966-05-12· cited 31×
• Eldredge v. Kamp Kachess Youth Services, Inc.
  Washington Supreme Court· 1978-08-24· cited 24×
• In Re the Welfare of Fisher
  Court of Appeals of Washington· 1982-04-16· cited 24×
• In Re the Welfare of Tarango
  Court of Appeals of Washington· 1979-04-18· cited 20×
• D.A.W. v. State
  Alaska Supreme Court· 1985-05-10· cited 17×
• Department of Social & Health Services v. Stratmeyer
  Court of Appeals of Washington· 1987-02-09· cited 1×