People ex rel. S.H.E.

Summary

The South Dakota Supreme Court affirmed the termination of a father's parental rights to four children who were enrolled members of the Oglala Sioux Tribe. The court held that the Department of Social Services made active efforts under the Indian Child Welfare Act, including efforts directed toward the children's mothers and the incarcerated father. The court also concluded that termination was the least restrictive alternative consistent with the children's best interests, rather than a guardianship.