SNK v. State
In SNK v. State, 78 P.3d 1032 (Wyo. 2003), SNK was the subject of a juvenile neglect proceeding and was eventually placed in foster care with a non-Indian family. Id. 78 P.3d at 1033-34.
Since SNK was an enrolled Northern Arapaho Tribe member, the Tribe intervened in the action pursuant to the Indian Child Welfare Act of 1978, 25 U.S.C. 1901 et seq. (hereinafter ICWA).
Despite the Tribe's intervention, the district court concluded that the ICWA was not applicable to the case. Id. 78 P.3d at 1034.
The Tribe appealed that determination. Id. 78 P.3d at 1035.
Shortly after the Tribe filed its appeal, SNK was removed from the non-Indian foster home and placed with her ex-stepfather. Id. 78 P.3d at 1038.
As a result, the Court dismissed the appeal, finding that "any determination by this court relating to the basis upon which the district court continued to place SNK in a non-Indian foster home ... is moot in that it would be wholly ineffectual and of no practical effect." Id.