In the Matter of April S., a Minor, 467 P.3d 1091

April S., a 17-year-old Alaska Native affiliated with the Native Village of Kotzebue, was taken into OCS custody and ultimately placed in a secure residential treatment facility in Utah.
After an injury at the Utah facility, April sought a placement review; her mother sought April's return, triggering ICWA removal-findings requirements at the .087 hearing.
OCS presented Jennifer Oxford, a Provo Canyon counselor, as a mental-health expert; Oxford had no professional knowledge of Inupiat/Kotzebue culture and had never been to Kotzebue.
April, her parents, and the Tribe objected that Oxford was not a "qualified expert witness" under ICWA because she lacked tribal cultural competence.
The superior court found Oxford qualified under ICWA, concluding tribal cultural knowledge was "plainly irrelevant" given April’s severe, acute mental-health risks (suicidality, recent self-harm, psychosis) and authorized continued secure placement with an immediate lateral transfer.
The Supreme Court affirmed, holding that ICWA expertise in tribal social and cultural standards is not required in limited cases where such knowledge is plainly irrelevant to the removal decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether testimony from a mental-health professional who lacks knowledge of the child’s Tribe satisfies ICWA’s "qualified expert witness" requirement for removal	April: Oxford is not qualified under ICWA because she lacks knowledge of Kotzebue culture; cultural factors can affect diagnosis and risk; ICWA requires cultural expertise	OCS: Oxford is qualified; cultural knowledge is unnecessary where the risk is tied to severe mental illness and danger that transcend culture	Court: Affirmed — Oxford qualified. ICWA experts need cultural knowledge except in limited circumstances; here cultural knowledge was plainly irrelevant given April’s acute, culture-independent mental-health risks.

Eva H. v. State, Dep't of Health & Social Servs., Office of Children's Servs., 436 P.3d 1050 (Alaska 2019) (interprets 2016 ICWA regulations and distinguishes when cultural expertise is required)
Bob S. v. State, Dep't of Health & Social Servs., Office of Children's Servs., 400 P.3d 99 (Alaska 2017) (standards for appellate review of ICWA-related findings)
Miss. Band of Choctaw Indians v. Holyfield, 490 U.S. 30 (1989) (ICWA’s congressional purpose to protect tribal relations and cultural standards)
In re Candace A., 332 P.3d 578 (Alaska 2014) (prior Alaska precedent recognizing exceptions when cultural expertise is not implicated)