both the state law requirements and the requirements in 25 U.S.C. § 1912(f). The Introductory Note to the Oklahoma Uniform Jury Instructions for Juvenile Cases, In re Oklahoma Uniform Jury Instructions for Juvenile Cases, 116 P.3d 119, 163 (Okla. 2005), explains its reasons for adopting the single beyond a reasonable doubt standard as follows: the prevailing practice in Oklahoma trial courts has been to use the reasonable doubt standard for both the state law requirements for termination of parental rights and the requirements in 25 U.S.C. § 1912(f); a single standard is less confusing for the jury than a dual standard; and the higher standard gives greatest effect to the ICWA and is less likely to result in reversal. 63 See In re Michael G., 74 Cal. Rptr. 2d 642 (Cal. Ct. App. 1998) (<HOLDING>); In the Interest of D.G., 679 N.W.2d 497 (S.D.
holding that a district court did not err by submitting a special verdict form to the jury this particular verdict form did not specify a standard of proof holding that the trial judge erred in instructing the jury on the physical endangerment portion of the statute when the defendant was charged only with the risk of injury to a child by doing an act likely to impair the morals of a child under the age of sixteen holding that the domicile of the child follows that of the parent with lawful custody holding the icwa beyond a reasonable doubt standard applies only to a special verdict question here special verdict question 7 relating to whether the return of custody of the child to the parent is likely to result in serious emotional or physical damage to the child recognizing that the child custody act required that the natural parent presumption must be seriously considered and heavily weighted in favor of the parent but that the presumption is rebutted if the clear and convincing evidence establishes that the best interest of the child is served by awarding custody to the third party