In re K.D
In In re K.D., 155 P.3d 634, 637 (Colo. Ct. App. 2007), a case involving the Indian Child Welfare Act (ICWA), a Colorado Court of Appeals concluded:
"A court may terminate parental rights without offering additional services when a social services department has expended substantial, but unsuccessful, efforts over several years to prevent the breakup of the family, and there is no reason to believe additional treatment would prevent the termination of parental rights. E.A. v. State Div. of Family & Youth Servs., 46 P.3d 986 (Alaska 2002); see also People in Interest of J.S.B., 2005 SD 3, 691 N.W.2d 611 (S.D. 2005) (court could terminate parental rights without additional services when a social services department has worked with a family for several years, the child had been removed from parental custody three times because of substance abuse related neglect, and the parents continued to use drugs)."