In A.A. v. State of Alaska, Department of Family & Youth Services, 982 P.2d 256 (Alaska, 1999), the Alaska Supreme Court, after considering its prior opinions approving the distinction between active and passive efforts and recognizing that there is "no pat formula" for distinguishing those efforts, 982 P.2d at 261, terminated a father's parental rights in spite of the State's "relatively passive" efforts, 982 P.2d at 262, concluding his unwillingness to participate in treatment while in prison and his lengthy sentence had justified the level of remedial services the State provided, and therefore it had fulfilled its duty under ICWA to make active efforts.