In Ronald H. v. Department of Health & Social Services, Office of Children’s Services, 490 P.3d 357 (Alaska 2021), the supreme court affirmed the lower court’s order to terminate a father’s parental rights, holding that the lower court did not err in finding that the Office of Children’s Services (OCS) had made sufficiently active efforts in providing services to prevent the breakup of the children’s family, as required by the Indian Child Welfare Act (ICWA). (Id. at 359–60). OCS petitioned to terminate the father’s parental rights because of his domestic violence and aggressive behavior. (Id. at 364). The lower court terminated his rights, and the father appealed, arguing that the lower court incorrectly found that OCS had met its active efforts burden. (Id.). The supreme court defined active efforts as when the state caseworker helps the parent meet the requirements of remedial and rehabilitative programs, rather than when the parent is required to meet them on his own. (Id. at 365). The court may consider a parent’s demonstrated lack of willingness to participate in treatment when determining whether OCS’s efforts were sufficiently active. (Id. at 366). The supreme court found that OCS made active efforts to help the father access rehabilitative services and psychological evaluation for medication, and that the father was unwilling and uncooperative in undertaking the tasks. (Id. at 367). Therefore, OCS met its active efforts burden, and the supreme court affirmed the lower court’s order to terminate the father’s parental rights. (Id. at 371).