A.M. v. State – Case Brief Summary (Alabama)

In A.M. v. State (Ala. 1997) 945 P.2d 296, the parent claimed the state did not meet its burden under Indian Child Welfare Act (ICWA) to provide active efforts when therapeutic services were provided by the department of corrections and not by the social services agency. (Id. at pp. 305-306.)

That court held that active intrusion into the department of corrections' therapeutic programs would have been "inappropriate and unreasonable, if not impermissible as a matter of law and impossible as a matter of practical reality." (Id. at p. 306.)

It was of no particular consequence whether the services were provided by the state's department of corrections or the state's department of family services. (Id. at p. 305.)