In In re C.H. (2000) 299 Mont. 62 997 P.2d 776, the lower court determined the child had likely suffered physical abuse and placed her with non-Indian foster parents at the age of three months. When the child was 15 months old, the lower court found good cause to deviate from the ICWA's placement preferences based in part on a finding that "as a result of minor's emotional bond with the foster family and the abuse she experienced early in life, she is at risk for developing an attachment disorder should she be removed" from her foster home. (997 P.2d at p. 781.) The Montana Supreme Court reversed, pointing to the lack of any testimony that the minor "was certain to develop an attachment disorder if removed from" the foster family's home. (Id. at p. 783.) The court went on to explain the certainty requirement by stating,"The risk that a child might develop such problems in the future is simply too nebulous and speculative a standard on which to determine that good cause exists to avoid the ICWA placement preferences. Indeed, it could be said that any child who has been abused, removed from its parents' care at a young age and placed in foster care might be at risk for developing emotional or psychological disorders. To allow such an indefinite standard to meet the good cause test for avoiding the preferences would essentially ignore the preferences set forth in 1915(a) of the ICWA." (Ibid.)