State In Interest of D.A.C
In State In Interest of D.A.C. (Utah App. 1997) 933 P.2d 993, a non-Indian mother sought to terminate the parental rights of her Indian former husband.
Noting that the mother had physical custody and the father reasonable visitation rights, the court defined the issue as whether the mother had proven beyond a reasonable doubt that the father's "continued legal rights to reasonable visitation would lead to serious emotional or physical harm of the children." ( Id. at p. 1002.)