Alaska Statutes

Alaska Stat. § 47.10.086 (2026)

Reasonable efforts

✓ current as of July 2026

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Sec. 47.10.086. Reasonable efforts.
(a) Except as provided in (b), (c), and (g) of this section, the department shall make timely, reasonable efforts to provide family support services to the child and to the parents or guardian of the child that are designed to prevent out-of-home placement of the child or to enable the safe return of the child to the family home, when appropriate, if the child is in an out-of-home placement. The department's duty to make reasonable efforts under this subsection includes the duty to
     (1) identify family support services that will assist the parent or guardian in remedying the conduct or conditions in the home that made the child a child in need of aid;

     (2) actively offer the parent or guardian, and refer the parent or guardian to, the services identified under (1) of this subsection; the department shall refer the parent or guardian to, and distribute to the parent or guardian information on, community-based family support services whenever community-based services are available and desired by the parent or guardian; the information may include the use of a power of attorney under AS 13.26.066 to select an individual to care for the child temporarily; and

     (3) document the department's actions that are taken under (1) and (2) of this subsection.

(b) If the court makes a finding at a hearing conducted under AS 47.10.080(l) that a parent or guardian has not sufficiently remedied the parent's or guardian's conduct or the conditions in the home despite reasonable efforts made by the department in accordance with this section, the court may conclude that continuation of reasonable efforts of the type described in (a) of this section are not in the best interests of the child. The department shall then make reasonable efforts to place the child in a timely manner in accordance with the permanent plan and to complete whatever steps are necessary to finalize the permanent placement of the child.

(c) The court may determine that reasonable efforts of the type described in (a) of this section are not required if the court has found by clear and convincing evidence that
     (1) the parent or guardian has subjected the child to circumstances that pose a substantial risk to the child's health or safety; these circumstances include abandonment, sexual abuse, torture, chronic mental injury, or chronic physical harm;

     (2) the parent or guardian has
          (A) committed homicide under AS 11.41.100 — 11.41.130 of a parent of the child or of a child;

          (B) aided or abetted, attempted, conspired, or solicited under AS 11.16 or AS 11.31 to commit a homicide described in (A) of this paragraph;

          (C) committed an assault that is a felony under AS 11.41.200 — 11.41.220 and results in serious physical injury to a child; or

          (D) committed the conduct described in (A) — (C) of this paragraph that violated a law or ordinance of another jurisdiction having elements similar to an offense described in (A) — (C) of this paragraph;

     (3) the parent or guardian has, during the 12 months preceding the permanency hearing, failed to comply with a court order to participate in family support services;

     (4) the department has conducted a reasonably diligent search over a time period of at least three months for an unidentified or absent parent and has failed to identify and locate the parent;

     (5) the parent or guardian is the sole caregiver of the child and the parent or guardian has a mental illness or mental deficiency of such nature and duration that, according to the statement of a psychologist or physician, the parent or guardian will be incapable of caring for the child without placing the child at substantial risk of physical or mental injury even if the department were to provide family support services to the parent or guardian for 12 months;

     (6) the parent or guardian has previously been convicted of a crime involving a child in this state or in another jurisdiction and, after the conviction, the child was returned to the custody of the parent or guardian and later removed because of an additional substantiated report of physical or sexual abuse by the parent or guardian;

     (7) a child has suffered substantial physical harm as the result of abusive or neglectful conduct by the parent or guardian or by a person known by the parent or guardian and the parent or guardian knew or reasonably should have known that the person was abusing the child;

     (8) the parental rights of the parent have been terminated with respect to another child because of child abuse or neglect, the parent has not remedied the conditions or conduct that led to the termination of parental rights, and the parent has demonstrated an inability to protect the child from substantial harm or the risk of substantial harm;

     (9) the child has been removed from the child's home on at least two previous occasions, family support services were offered or provided to the parent or guardian at those times, and the parent or guardian has demonstrated an inability to protect the child from substantial harm or the risk of substantial harm;

     (10) the parent or guardian is incarcerated and is unavailable to care for the child during a significant period of the child's minority, considering the child's age and need for care by an adult; or

     (11) the parent or guardian
          (A) has sexually abused the child or another child of the parent or guardian; or

          (B) is registered or required to register as a sex offender or child kidnapper under AS 12.63.

(d) If the court determines under (b) or (c) of this section that reasonable efforts under (a) of this section are not required to be provided,
     (1) the court shall hold a permanency hearing for the child within 30 days after the determination; and

     (2) the department shall make reasonable efforts to place the child in a timely manner in accordance with the permanency plan, and complete whatever steps are necessary to finalize the permanent placement of the child.

(e) The department may develop and implement an alternative permanency plan for the child while the department is also making reasonable efforts to return the child to the child's family under (a) of this section.

(f) In making determinations and reasonable efforts under this section, the primary consideration is the child's best interests.

(g) The department is not required to make reasonable efforts of the type described in (a) of this section if the department took emergency custody of an infant under AS 47.10.142 after the infant was abandoned safely within the meaning of AS 47.10.013(c).

(h) The department shall engage a child who is 14 years of age or older in the development or revision of a case plan, permanency goal, or alternative permanency plan for the child. The department shall also allow the child to select not more than two adults to participate in the development or revision of the plan in addition to the child's foster parents or department employees who are supervising the care of the child. The department may reject an adult selected by the child if the department has good cause to believe that the adult will not act in the best interests of the child. If the department rejects an adult, the child may select another adult. The child may designate one of the adults to be the child's advisor, and the advisor may advocate for the child.

Notes of Decisions

Cited in 174 cases (60 in the last 5 years), 2000–2026 · leading case: Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003).

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Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). · cites it 62× “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). · cites it 29× “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). · cites it 27× “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). · cites it 12× “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

Jon S. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 212 P.3d 756 (Alaska 2009). · cites it 8× “Our conclusion that the superior court did not err in holding that the state met its active efforts requirement also disposes of Jon's argument that the state failed to meet the lower "reasonable efforts" requirement in AS 47.10.086. Cf. Winston J. v. State, Dep't of Health &…”

Sherman B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 310 P.3d 943 (Alaska 2013). · cites it 6× “16 Third, the court must find by clear and convincing evidence that OCS has made reasonable efforts, pursuant to AS 47.10.086, in support of reunification.”

Jeff AC, Jr. v. State, 117 P.3d 697 (Alaska 2005). · cites it 4× “The termination statute requires the state to prove by a preponderance of the evidence that it has "complied with the provisions of AS 47.10.086 concerning reasonable efforts.”

Martin N. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 79 P.3d 50 (Alaska 2003). · cites it 3× “088(a)(2) requires the court to find by a preponderance of the evidence that DFYS has made reasonable efforts to assist the parent in remedying harmful conduct or conditions, as required by AS 47.10.086. The superior court found that DFYS did all it could reasonably do until its…”

Casey K. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 311 P.3d 637 (Alaska 2013). · cites it 4× “" The superior court also found by clear and convincing evidence that Casey had not "remedied the conduct or conditions in the home that put the child at substantial risk of harm," and that OCS "made timely and reasonable efforts as required by AS 47.10.086 to effectuate…”

Burke P. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 162 P.3d 1239 (Alaska 2007). · cites it 4× “When interpreting what types of reunification efforts are required under AS 47.10.086(2), 21 we have stated that OCS must *1245 provide a parent with a "reasonable opportunity .”

J.H. v. State, Dep't of Health & Soc. Servs., 30 P.3d 79 (Alaska 2001). · cites it 5× “088(a)(2) requires the court to find "by preponderance of the evidence that the department has complied with the provisions of AS 47.10.086 concerning reasonable efforts.”

Sylvia v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 343 P.3d 425 (Alaska 2015). · cites it 3× “Sylvia asserts that she would have pursued a different trial strategy had she known that OCS intended to assert mental illness as a basis for termination, but she gives no specifics.”

Show all 174 citing cases →

— Alaska Stat. § 47.10.086(0)(3) — 1 case

Sherman B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 310 P.3d 943 (Alaska 2013). “16 Third, the court must find by clear and convincing evidence that OCS has made reasonable efforts, pursuant to AS 47.10.086, in support of reunification.”

— Alaska Stat. § 47.10.086(1) — 2 cases

Sherry R. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 332 P.3d 1268 (Alaska 2014).

Donny P. v. State of Alaska, DFCS, OCS (Alaska 2026).

— Alaska Stat. § 47.10.086(2) — 1 case

Burke P. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 162 P.3d 1239 (Alaska 2007). “When interpreting what types of reunification efforts are required under AS 47.10.086(2), 21 we have stated that OCS must *1245 provide a parent with a "reasonable opportunity .”

— Alaska Stat. § 47.10.086(a) — 101 cases

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

Jon S. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 212 P.3d 756 (Alaska 2009). “Our conclusion that the superior court did not err in holding that the state met its active efforts requirement also disposes of Jon's argument that the state failed to meet the lower "reasonable efforts" requirement in AS 47.10.086. Cf. Winston J. v. State, Dep't of Health &…”

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

— Alaska Stat. § 47.10.086(a)(1) — 26 cases

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Annette H. v. State of Alaska, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 450 P.3d 259 (Alaska 2019).

Cora G. v. State of Alaska, DHSS, OCS, Justin D. v. State of Alaska, DHSS, OCS, 461 P.3d 1265 (Alaska 2020).

— Alaska Stat. § 47.10.086(a)(2) — 5 cases

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Christa L. v. State of Alaska, Dep't of Fam. & Cmty. Servs., Off. of Child.'s Servs. (Alaska 2023).

Wyatt W. (Father) v. State of Alaska, DHSS, OCS, Trena S.(Mother) v. State of Alaska, DHSS, OCS (Alaska 2018).

Jack C. (Father) v. State of Alaska, DHSS, OCS (Alaska 2017).

— Alaska Stat. § 47.10.086(a)(3) — 8 cases

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

Bill S. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 436 P.3d 976 (Alaska 2019).

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Ronan F. v. State of Alaska, DHSS, OCS, Elena F. v. State of Alaska, DFCS, OCS, 539 P.3d 507 (Alaska 2023).

— Alaska Stat. § 47.10.086(a)(l) — 1 case

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

— Alaska Stat. § 47.10.086(b) — 9 cases

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

In Re the Adoption of Missy M., 133 P.3d 645 (Alaska 2006).

J.H. v. State, Dep't of Health & Soc. Servs., 30 P.3d 79 (Alaska 2001). “088(a)(2) requires the court to find "by preponderance of the evidence that the department has complied with the provisions of AS 47.10.086 concerning reasonable efforts.”

Moira M. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 370 P.3d 595 (Alaska 2016).

— Alaska Stat. § 47.10.086(c) — 9 cases

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Audrey H. v. State, Off. of Child.'s Servs., 188 P.3d 668 (Alaska 2008). “011; (2) the parent has not remedied the conduct or conditions in the home that place the child at substantial risk of harm; and (8) OCS has made reasonable efforts under AS 47.10.086 to provide services to the family to prevent out-of-home placement of the child or to enable…”

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Moira M. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 370 P.3d 595 (Alaska 2016).

C.W. v. State, Dep't of Health & Soc. Servs., 23 P.3d 52 (Alaska 2001).

— Alaska Stat. § 47.10.086(c)(1) — 8 cases

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Vivian P. v. State, Dep't of Health & Soc. Servs., 78 P.3d 703 (Alaska 2003).

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

Moira M. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 370 P.3d 595 (Alaska 2016).

— Alaska Stat. § 47.10.086(c)(10) — 7 cases

Frank E. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 77 P.3d 715 (Alaska 2003). “hild at substantial risk of harm; or (ii) has failed, within a reasonable time, to remedy the conduct or conditions in the home that place the child in substantial risk so that returning the child to the parent would place the child at substantial risk of physical or mental…”

Stanley B. v. State, Dfys, 93 P.3d 403 (Alaska 2004).

Martin N. v. State, Dep't of Health & Soc. Servs., Div. of Fam. & Youth Servs., 79 P.3d 50 (Alaska 2003). “088(a)(2) requires the court to find by a preponderance of the evidence that DFYS has made reasonable efforts to assist the parent in remedying harmful conduct or conditions, as required by AS 47.10.086. The superior court found that DFYS did all it could reasonably do until its…”

Dashiell v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 222 P.3d 841 (Alaska 2009).

Samuel H. v. State, Off. of Child.'s Servs., 175 P.3d 1269 (Alaska 2008).

— Alaska Stat. § 47.10.086(c)(11)(B) — 1 case

Patterson v. Walker, 429 P.3d 829 (Alaska 2018).

— Alaska Stat. § 47.10.086(c)(2)(A) — 1 case

Mona J. v. State of Alaska, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 511 P.3d 553 (Alaska 2022).

— Alaska Stat. § 47.10.086(c)(7) — 1 case

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

— Alaska Stat. § 47.10.086(c)(8) — 1 case

Sherman B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 310 P.3d 943 (Alaska 2013). “16 Third, the court must find by clear and convincing evidence that OCS has made reasonable efforts, pursuant to AS 47.10.086, in support of reunification.”

— Alaska Stat. § 47.10.086(d)(1) — 1 case

Vivian P. v. State, Dep't of Health & Soc. Servs., 78 P.3d 703 (Alaska 2003).

— Alaska Stat. § 47.10.086(e) — 1 case

L.H. (Father) v. State of Alaska, OCS (Alaska 2012).

— Alaska Stat. § 47.10.086(e)(1) — 1 case

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

— Alaska Stat. § 47.10.086(f) — 18 cases

Joy B. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 382 P.3d 1154 (Alaska 2016). “” The superior court next found, by clear and convincing evidence, that OCS had made reasonable efforts to reunite the family as required under AS 47.10.086. The court cited a number of the specific efforts OCS had made, including offering supervised family contact, conducting…”

Kylie L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 407 P.3d 442 (Alaska 2017). “088(a)(8) requires the trial court to determine by clear and convincing evidence that OCS has complied with AS 47.10.086’s provisions; AS 47.10.086(a) provides that OCS “shall make timely, reasonable efforts” except, in relevant part, as provided in subsection (c), 25 If the…”

Sherry R. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 332 P.3d 1268 (Alaska 2014).

Jimmy E. v. State of Alaska, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., Allie P. v. State of Alaska, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 529 P.3d 504 (Alaska 2023).

Jonah B. v. State of Alaska, Dep't of Fam. & Cmty. Servics, Off. of Child.'s Servs. (Alaska 2023).

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