In re S.B.R
In In re S.B.R., 43 Wn. App. 622, 719 P.2d 154 (WashCtApp 1986), the court ruled that the rights acquired by the grandparents qualified as an Indian Child Welfare Act (ICWA) guardianship.
Because the father could not have the child returned upon demand, but could only seek to modify the guardianship decree, this was a placement proceeding contemplated by ICWA.