active efforts requirement in Michigan

5 Michigan opinions name it 1 courts 2008–2024 2 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

Case	Followed	Cited
In re Englandgreen michctapp · 2016 · cited in 3 Michigan opinions naming this issue, 2018–2023 2 sentences 2023See In re England, 314 Mich App 245, 259 ; 887 NW2d 10 (2016).1 Respondent submits that petitioner, the Department of Health and Human Services (DHHS), did not establish the statutory grounds for termination beyond a reasonable doubt and also argues that termination was improper because the active efforts requirement as discussed in In re JL, 483 Mich 300 ; 770 NW2d 853 (2009), was violated. 2023See In re England, 314 Mich App 245, 259 ; 887 NW2d 10 (2016).1 Respondent submits that petitioner, the Department of Health and Human Services (DHHS), did not establish the statutory grounds for termination beyond a reasonable doubt and also argues that termination was improper because the active efforts requirement as discussed in In re JL, 483 Mich 300 ; 770 NW2d 853 (2009), was violated.	1	3
In Re JSgreen oklacivapp · 2008 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008See also In re Walter W, 274 Neb 859, 862-863; 744 NW2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re JS, 177 P3d 590, 591 (Okla Civ App, 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed).	1	1
In Re Doughertygreen michctapp · 1999 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008In re SD, supra at 244.	1	1
In Re Michael G.green calctapp · 1998 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1
People in Interest of SRgreen sd · 1982 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2	1	1
In Re Trejo Minorsred mich · 2000 · cited in 1 Michigan opinions naming this issue, 2008–2008 1 sentence 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1
People v. Rogersgreen mich · 1991 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1
People Ex Rel. Kdgreen coloctapp · 2007 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1
In Re Interest of Walter W.green neb · 2008 · cited in 1 Michigan opinions naming this issue, 2008–2008 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2	1	1
People Ex Rel. Jsb, Jr.green sd · 2005 · cited in 1 Michigan opinions naming this issue, 2008–2008 1 sentence 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1
People in Interest of P.B.green sd · 1985 · cited in 1 Michigan opinions naming this issue, 2008–2008 1 sentence 2008See also In re Michael G., 63 Cal.App.4th 700, 709-712 , 74 Cal.Rptr.2d 642 (1998) (rejecting the line of authorities that impose a heightened burden of proof on determinations under § 1912[d]). [23] In re Walter W., supra at 864-865, 744 N.W.2d 55 . [24] Id. at 865 , 744 N.W.2d 55 . [25] Id. [26] MCR 7.215(J)(1). [27] See In re Trejo, Minors, supra at 356-357, 612 N.W.2d 407 . [28] See In re Walter W, supra at 865, 744 N.W.2d 55 (noting that the language "sets out praiseworthy but vague goals for the courts to enforce," which fail to give guidance "in determining whether the Department's effo	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (3)

Case	Cited	Years
In Re JL green mich · 2009 2 sentences 2024While the active-efforts bar is high, “there comes a time when the [DHHS] or the tribe may justifiably pursue termination without providing additional services.” In re JL, 483 Mich at 326-327 . 2023See In re England, 314 Mich App 245, 259 ; 887 NW2d 10 (2016).1 Respondent submits that petitioner, the Department of Health and Human Services (DHHS), did not establish the statutory grounds for termination beyond a reasonable doubt and also argues that termination was improper because the active efforts requirement as discussed in In re JL, 483 Mich 300 ; 770 NW2d 853 (2009), was violated.	2	2023–2024
In Re Morgan green michctapp · 1985 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2	1	2008–2008
In Re Kreft green michctapp · 1986 2 sentences 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2 2008See also In re Walter W., 274 Neb. 859, 862-863 , 744 N.W.2d 55 (2008) (noting that, in addition to the state elements required to terminate parental rights, the ICWA imposes two additional elements: the active efforts element and the serious emotional or physical damage element); In re J.S., 177 P.3d 590 , 591 (Okla.Civ.App., 2008) (noting that the active efforts requirement is a predicate finding that the trial court must make before a termination case may proceed). [16] In re SD, supra at 244, 599 N.W.2d 772 . [17] See 25 USC 1912(f). [18] See In re Kreft, 148 Mich.App. 682, 693 , 384 N.W.2	1	2008–2008

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 712A.19b (5) MI § Mich. Comp. Laws § 712B.1 (4) MI § Mich. Comp. Laws § 712B.15 (4) MI § Mich. Comp. Laws § 712B.3 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

AK 33 (2001–2026) WA 11 (2017–2025) CO 9 (2007–2025) IL 6 (2002–2011) UT 5 (2008–2016) MI 5 (2008–2024) NE 5 (2014–2021) IA 4 (2011–2025) NM 4 (2015–2023) CA 4 (2006–2020) MT 3 (2013–2018) SD 3 (2012–2024) OK 3 (2011–2015) AZ 2 (2017–2018) OR 2 (2012–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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