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14 Alaska opinions name it 1 courts 2002–2026 6 in the last five years
The cases below were cited by Alaska 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.
| Case | Followed | Cited |
|---|---|---|
Barbara P. v. State, Department of Health & Social Servicesgreen2 sentences2022OCS developed a series of case plans for Alyse that addressed the issues that led to Octavia’s removal; made referrals to services and classes while she was incarcerated; contacted her often to discuss her progress; and made referrals for a variety of other services once she was released, none of which she 18 Id. 19 234 P.3d 1245, 1261-63 (Alaska 2010). 2018Servs., Office of Children’s Servs., 234 P.3d 1245 , 1262 n.48 (Alaska 2010) (“Services offered by [DOC] are considered efforts of OCS for purposes of the reasonable efforts analysis.”). -8- 1689 First, Justin argues that the two or three visits OCS facilitated during the ten months he was incarcerated did not constitute reasonable efforts. | 2 | 2 |
Casey K. v. State, Dept. of Health & Social Services, Office of Children's Servicesgreen1 sentence2023Servs., 311 P.3d 637, 644 (Alaska 2013). 26 Further, Russel’s argument suggests that if OCS did not make reasonable efforts to prevent Hillary’s out-of-home placement, no amount of efforts after removal would satisfy the reasonable efforts requirement. | 1 | 1 |
Dashiell R. v. Ocsgreen1 sentence2023Servs., Off. of Child.’s Servs., 222 P.3d 841, 849-50 (Alaska 2009). -11- 2001 Even after release, Jonah had no reason to know that satisfying his parole conditions could partially satisfy his case plan requirements until less than three months before trial. | 1 | 1 |
Sylvia v. State, Department of Health & Social Services, Office of Children's Servicesgreen1 sentence2023Servs, Off. of Child.’s Servs., 343 P.3d 425, 432 (Alaska 2015) (noting reunification efforts regarding non- Indian child “need only be reasonable under the circumstances, depending” in part on parent’s level of cooperation); Sherman B. v. State, Dep’t of Health & Soc. | 1 | 1 |
Cora G. v. State of Alaska, DHSS, OCS, Justin D. v. State of Alaska, DHSS, OCSgreen1 sentence2022Servs., Off. of Child.’s Servs., 461 P.3d 1265, 1276 (Alaska 2020) (explaining we independently review legal questions, including whether factual findings meet parental rights termination rule requirements). 5 See Violet C. v. State, Dep’t of Health & Soc. | 1 | 1 |
Shirley M. v. State, Dept. of Health & Social Services, Office of Children's Servicesgreen1 sentence2016See, eg., Shirley M., 342 P.3d at 1241-42 ; Sherman B., 290 P.3d at 432-33 ; Sean B., 251 P.3d at 338-39 . | 1 | 1 |
Kyle S. v. State, Dept. of Health & Social Services, Office of Children's Servicesgreen1 sentence2015Servs., 309 P.3d 1262, 1268 (Alaska 2013) (alteration in original) (quoting Winston J. v. State, Dep’t of Health & Soc. | 1 | 1 |
JS v. Stategreen2 sentences2003DFYS must first ask a superior court for a reasonable efforts hearing before ceasing to make such efforts. 15 . 50 P.3d 388 , 389, 391 (Alaska 2002). 16 . 2003Id. at 390. 17 . | 1 | 1 |
Wyatt v. Estate of Wyattgreen1 sentence2003Wyatt v. Wyatt, 65 P.3d 825, 831 (Alaska 2003). . 982 P.2d 256 , 260 (Alaska 1999). . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Alaska. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Duke S. v. State, Dept. of Health & Social Services, Office of Children's Services
green
2 sentences2026Servs., Off. of Child.’s Servs., 433 P.3d 1127 (Alaska 2018). 21 Id. at 1137 . - 14 - 2130 We are not convinced by Donny’s comparison of his case with Duke S. OCS made significantly greater efforts toward Donny here than were made in that case. 22 Instead, we consider Donny’s case more analogous to Barbara P. 23 Here, as in Barbara P., OCS developed and updated a tailored case plan, made referrals for multiple meaningful assessments and services, and arranged supervised visitation.24 And here, as in Barbara P., the father “made little progress in completing his case plan requirements.” 25 Inde 2026Servs., Off. of Child.’s Servs., 433 P.3d 1127 (Alaska 2018). 21 Id. at 1137 . - 14 - 2130 We are not convinced by Donny’s comparison of his case with Duke S. OCS made significantly greater efforts toward Donny here than were made in that case. 22 Instead, we consider Donny’s case more analogous to Barbara P. 23 Here, as in Barbara P., OCS developed and updated a tailored case plan, made referrals for multiple meaningful assessments and services, and arranged supervised visitation.24 And here, as in Barbara P., the father “made little progress in completing his case plan requirements.” 25 Inde | 1 | 2026–2026 |
Frank E. v. State, Department of Health & Social Services, Division of Family & Youth Services
green
1 sentence2023Even if such evidence existed, the fact that Jonah was not made aware of his case plan requirements while he was incarcerated would limit the extent to which services provided by correctional authorities could satisfy the reasonable efforts requirement. 18 Id. 19 Although there was no testimony on this point, a “Summary of Efforts” admitted in evidence indicates the visitation was scheduled to begin October 19. 20 Dashiell R. v. State, Dep’t of Health & Soc. | 1 | 2023–2023 |
Vivian P. v. State, Department of Health & Social Services
green
1 sentence2017But in that case the trial court found OCS was excused from the reasonable efforts requirement on the basis of AS 47.10.086(c)(1) because the parent had subjected the child to "chronic mental injury or chronic physical harm." Id. at 708 . 25 . | 1 | 2017–2017 |
Sherman B. v. State, Department of Health & Social Services
green
1 sentence2016See, eg., Shirley M., 342 P.3d at 1241-42 ; Sherman B., 290 P.3d at 432-33 ; Sean B., 251 P.3d at 338-39 . | 1 | 2016–2016 |
Sean B. v. State, Department of Health & Social Services
green
1 sentence2016See, eg., Shirley M., 342 P.3d at 1241-42 ; Sherman B., 290 P.3d at 432-33 ; Sean B., 251 P.3d at 338-39 . | 1 | 2016–2016 |
Christensen v. Alaska Sales & Service, Inc.
green
1 sentence2015Christensen, 335 P.3d at 516 . 19 . | 1 | 2015–2015 |
AA v. State
green
1 sentence2003Wyatt v. Wyatt, 65 P.3d 825, 831 (Alaska 2003). . 982 P.2d 256 , 260 (Alaska 1999). . | 1 | 2003–2003 |
L.G. v. State, Department of Health & Social Services
green
2 sentences2002Because we hold that the state was not required to make active efforts, it is unnecessary to reach these two issues. [17] 14 P.3d 946 (Alaska 2000). [18] Id. at 953 . [19] Id. [20] 25 U.S.C. § 1911 (b) (2000) provides in relevant part: (b) Transfer of proceedings; declination by tribal court In any State court proceeding for the foster care placement of, or termination of parental rights to, an Indian child not domiciled or residing within the reservation of the Indian child's tribe, the court, in the absence of good cause to the contrary, shall transfer such proceeding to the jurisdiction of 2002Because we hold that the state was not required to make active efforts, it is unnecessary to reach these two issues. [17] 14 P.3d 946 (Alaska 2000). [18] Id. at 953 . [19] Id. [20] 25 U.S.C. § 1911 (b) (2000) provides in relevant part: (b) Transfer of proceedings; declination by tribal court In any State court proceeding for the foster care placement of, or termination of parental rights to, an Indian child not domiciled or residing within the reservation of the Indian child's tribe, the court, in the absence of good cause to the contrary, shall transfer such proceeding to the jurisdiction of | 1 | 2002–2002 |
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.
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.