protections afforded by ICWA, section 1912(d) requires that, before a parent’s rights may be terminated, a court must determine if active efforts to provide remedial services have been made. Specifically, that section states: Any party seeking to effect a ... termination of parental rights to[ ] an Indian child under State law shall satisfy the court that active efforts have been made to provide remedial services and rehabilitative programs designed to prevent the breakup of the Indian family and that these efforts have proved unsuccessful. 25 U.S.C. § 1912(d). The remedial efforts should be directed at remedying the reason that led to removal. Adoption of Hannah S., 142 Cal.App.4th 988, 48 Cal.Rptr.3d 605, 612 (2006); see also Matter of Baby Boy Doe, 127 Idaho 452, 902 P.2d 477 (1995) (<HOLDING>). The legislative history of subsection (d)
holding the record did not contain enough facts to determine whether the statute was constitutional as applied to the particular facts and circumstances of the case holding defense applicable to both types of claims holding that the types of remedial and rehabilitative services to be required under icwa depend on the facts of the case holding that inmates in arizona jails and prisons cannot be treated differently based on a distinction between the rehabilitative programs available in the two types of institutions holding that even under the higher active efforts burden required in indian child welfare act icwa cases the fact that ocs failed to make efforts during three of the 26 months it was involved in the case was not determinative