when an express cause of action already exists in another section of the same statute. See, e.g., id. at 572, 99 S.Ct. 2479. When Congress wished to provide a cause of action, it apparently knew how to do so and would have done so in a section of the statute immediately following. Congress knew how to create a cause of action in the statute and did so. Section 1914 expressly creates a cause of action for violations of §§ 1911-1913. Furthermore, at least two courts have held that a claim is not viable under § 1915. See B.R.T. v. Executive Dir. of Soc. Serv. Bd. of N.D., 391 N.W.2d 594, 601 (N.D. 1986) (showing a violation of § 1915 will not invalidate termination of parental rights); State ex rel. Juvenile Dept. of Multnomah County v. Woodruff, 108 Or. App. 352, 816 P.2d 623, 625 (1991) (<HOLDING>). Also, in support of its assertion that this
holding noncompliance with  1915 placement preferences in not a basis to invalidate termination of parental rights holding that foster parents have standing to intervene to seek termination of parental rights recognizing this substantial interest in context of termination of parental rights holding that trial court erred in granting petition for termination of parental rights based on noncompliance with case plan when case plan was not filed and approved by the court until seven months after petition for termination was filed holding that a respondent in a termination of parental rights proceeding may not file a counterclaim