OUR COMMENTS Concerning ICWA Rules Proposed by the BIA –

Ms. Rodina Cave and Ms. Elizabeth Appel
Office of Regulatory Affairs & Collaborative Action
Indian Affairs, U.S. Department of the Interior
1849 C Street NW, MS 3642
Washington, DC 20240

Re: Notice of Proposed Rulemaking—Regulations for State Courts and Agencies in Indian Child Custody Proceedings—RIN 1076-AF25—Federal Register (March 20, 2015)

Dear Ms. Cave and Ms. Appel,

Thank you for allowing our organization, the Christian Alliance for Indian Child Welfare, to meet with you on Monday, May 4, 2015, concerning the Notice of Public Rulemaking (NPRM) regarding Regulations for State Courts and Agencies in Indian Child Custody Proceedings.

Please accept this letter as our official comments in the matter regarding said rulemaking for State Courts and Agencies in Indian Child Custody Proceedings.

As I explained in our meeting, my husband, a member of the Minnesota Chippewa Tribe, began speaking against the Indian Child Welfare Act and its usurpation of his rights almost twenty years ago. After dozens of families found our website and started writing to us from across the country, telling us of how their children were being hurt by the ICWA, our organization arose.

In April of 2014, our organization commented during the initial discussions concerning ICWA guidelines. I was dismayed to hear the hosts of a Thursday, April 24, 2014 listening session state a belief that tribal leaders are the only real ‘stakeholders’ in the ICWA issue. This infers that children, their parents, and extended family are not ‘stakeholders’ in their own lives. It infers that tribal members and potential tribal members are chattel for tribal leaders, and not the individuals of varied backgrounds, worldviews, heritages and needs that they are.

Our membership and I are ‘stakeholders’ in all decisions concerning ICWA. Our voices, feelings and needs are just as important as those of tribal leaders. Our children deserve a level of protection and services equal to that of non-tribal enrolled children.

Fortunately, I have learned over the last few weeks that several in Congress recognize us as stakeholders, value our children for their individuality, and have been stunned by the tenor of the proposed ICWA guidelines. Several Congressmen, in discussion, have recognized the tyranny of the rules as well as the unconstitutionality.

Tribal members who have rejected tribal jurisdiction, non-member parents of heritage who rejected the reservation system and/or have never lived under it, and hundreds of thousands of non-Indians across the nation are in fact “stakeholders” in this law – whether the federal government recognizes it or not.

Non-Indian stakeholders include non-Indian birth moms, dads, grandparents, aunts, uncles, and cousins of children adversely affected by the Indian Child Welfare Act. There are hundreds of thousands of them. You cannot say these families are not “stakeholders” if they have to fight a tribal government over rights to their own children and grandchildren.

Families are the center of all cultures. Our communities and children are gifts from the Lord God. The Indian Child Welfare Act has not been protecting our families. It has been harming them.

Federal and tribal governments do not have a right to interfere with our children or mandate political affiliations that parents do not agree with. Over the last twenty years, family upon family have contacted our organization with stories of how they have been hurt by the Indian Child Welfare Act of 1978 (ICWA).

Many parents have taken their children and left Indian Country for justified reasons related to tribal government corruption and crime. The BIA has been made aware of documented and rampant sexual abuse of children on many reservations. It is appalling that, in light of these documented reports of rampant abuse and suicides and the circumstances surrounding them, the BIA is proposing rules that will only increase risk for our children, as well as infringe on personal, parental, and privacy rights of families.

Substantive ICWA regulations that provide rules for its implementation in state courts and by state and public agencies will only hurt our children and families more.

The ICWA has been applied in custody cases for almost four decades now. The ICWA has led to the unnecessary break up of families and placement instability for children of varied heritage. Native children and families need agencies and courts that implement ICWA to understand just how much damage this law has done. If the ICWA’s original purpose was truly to protect children, it has not been doing so.

If the BIA has the authority to issue regulations, we are asking you not to use that authority to continue to hurt our families.

We have current cases of extended birth family having to fight tribal governments for their own children. Children have become footballs for tribal leaders seeking revenge, money or other purposes. Reservations currently attacking the rights and decisions of “stakeholder” birth family include Cheyenne River, the Cherokee Nation, and Warm Springs, among others.

Further, the federal government is mandating jurisdiction of children to a political entity many families have no connection to outside of mutual ancestors. It is assumed by some that this law only affects persons who have chosen to be part of that political entity, but it affects many who have chosen not to be – and if these rules go into effect, will interfere with the lives of many times more children and families.

Neither Congress, the BIA, nor tribal governments should be mandating race-based political affiliation for our children. Many tribal members or potential tribal members who are part of our organization made conscience and purposeful decisions to distance themselves from tribal government due to crime and corruption within Indian Country, including crime and corruption by their tribal councils and governments.

Many, many more children have left Indian Country in the custody of their parents than have left in the custody of social services or adoption agencies.

People make various choices in how they live their lives. Many U.S. citizens of Native American heritage have purposefully chosen not to live under the auspices of tribal and federal government – nor in the limited “cultural” box defined by entities such as NICWA, NARF and the Casey Foundation – despite the many attempts by these organizations to close people into that box.

According to the last two U.S. censuses, Seventy-five percent of those considered Native American do not live in Indian Country. Further, multi-heritage families are the norm. The majority of children affected by ICWA have OTHER extended family, roots, traditions, and worldviews – all equally important and acceptable.

Neither Congress, the BIA, nor tribal governments have a right to decide which worldview or ‘culture’ should be primary for our children.

The guidelines and rules claim to clarify existing law for the protection of families – despite marginalizing the rights of birth parents as well the reality of extended non-tribal birth family. There is no acknowledgement that the vast majority of eligible children are multi-racial and 75% of eligible families live outside of Indian Country.

Tribal entities use misleading statistics, such as that “more than 50% of Native kids adopted are placed in non-Native homes” – while failing to mention that many of those children are of primarily non-native heritage and have no trouble living amongst others of their primary heritage.

In the famous case “Adoptive Couple vs. Baby Girl,” the child in question was 74% Caucasian, 25% Latino and 1% Cherokee Nation. If one believes that children need to be placed in homes with heritages reflecting their primary heritage, then her placement in a Caucasian home was fitting to her primary heritage.

We, on the other hand, are primarily multi-heritage families and do not believe claims that it is vital to match heritages. We are not as concerned with matching ethnicity and heritage as much as we are concerned with matching the child with families and environments they are familiar and comfortable with. Our heritage does not define us. It is merely an interesting data point. All men are created equal, and we yearn to be judged – as wisely noted by Martin Luther King – on the content of our character, not the color of our skin.

Bad enough our federal government has forced the children of some purposefully distanced families of 100% tribal heritage into a political relationship with tribal government, but our federal government has been requiring children of scant heritage to be placed before tribal entities for decisions concerning the most important aspect of their private lives – their home and family – as well.

Tribally appointed decision makers frequently interfere in families despite knowing little more about a child than their percentage of heritage. It is impossible for any entity to know the emotions and needs of a child if they do not have active knowledge of or relationship with that particular child.

But many of the decision makers as well as the BIA do not appear to want to know more about the children they are corralling – as the rules mandate that no “best interest” argument outside of ICWA needs to be entertained. The true aspects of that individual’s life and personality appear irrelevant.

Let us be clear that what tribal governments, NICWA, NARF, NCAI and the Casey Foundation describe as the emotional needs of children with Native American heritage do not reflect my children or the children of our membership. If these entities are unable to accurately describe the needs, thoughts and feelings of our children, they are most certainly unable to speak for them.

Forty years ago, ICWA was enacted under the premise that it would keep children in their families and in the culture and environment to which they were most accustomed. These new BIA rules prove that keeping children in their accustomed environment is irrelevant to ICWA and its supporters.

These rules clearly mandate seeking out children who have had absolutely no evident connection to or need for Indian Country, notifying any potential tribal government of the child’s existence, and giving that tribal government the option to steal that child away from the only home, family, culture and environment the child has ever known.

The Casey Foundation, NICWA, NARF and some tribal governments are now claiming this is necessary due to an unscientific “study” purporting the existence of a condition they call “Split Feather” syndrome. No one articulates clearly what this syndrome derives from, but they don’t appear to be talking about a virus. What appears suggested is either that it is a spiritual issue or that all children of even the slightest heritage have some kind of ‘inherent gene’ that will cause the child to suffer if not connected to tribal government.

If the suggestion is that it is genetic, this is the epitome of racism – the suggestion that persons of a certain heritage are inherently and genetically different from the rest of the human race.

Thankfully, the Human Genome project – a scientific study mapping all human DNA – has put to rest all such incredible notions.

The Genome project proved that no separate classifiable subspecies (race) exists within humans – meaning, there is no genetic ‘racial’ difference between a person of Indian heritage and a person of English heritage.

In other words, we are all brothers and sisters – having come from the same seed. Differences found in individuals are ‘familial,’ i.e.: family related genetic blueprints, not tied to any ‘race’ gene. Eye color, the shape of a cheekbone and texture of hair are all distinct genes, separate from each other and passed down from both parents to their child. European physical traits pass equally with all others.

If they are not suggesting the condition is genetic, the only other source of this “syndrome” they attribute to children who have not had any connection to Indian Country must be spiritual. If this is what ICWA supporters are suggesting is the source of their syndrome, CAICW would be interested in seeing the study supporting the theory.

Federal government appears to cater to tribal government demand for jurisdiction over our children – even when clearly contrary to a child’s well-being – purely for reasons of political expediency. “Stakeholder” arguments dispelled, we would like to know why federal government assumes the right to use our children as chess pieces – political stakes – as they negotiate land and treaty issues with tribal governments. Federal government should be aware that as they continue to “lower the stakes” and interfere with an increasing number of primarily ‘non-tribal’ children, and increasing number of non-tribal taxpayers will be affected.

What is clear is that tribal governments, NICWA, NARF, NCAI and the Casey Foundation all receive large amounts of money in relation to enrolled children. It is no surprise that an interest in funds would affect an appetite for more children.

The proposed ICWA Rules are dangerous to the well-being of our children. They state, in part:

1. It doesn’t matter if the child has never been connected to Indian Country.
– Our response: It does matter. Our children should not be forced into drastically different and frightening home situations. We oppose this mandate over our families.

2. There is no need for a certain blood quantum. Tribal governments have complete say over whether a child is a member and subject to ICWA.
– Our response: Families should have final say concerning membership – not tribal officials. We oppose this unwarranted and unwanted mandate over our families.

3. EVERY child custody case MUST be vetted to see if it is ICWA, because there are so many of scant heritage who have never been near Indian Country and thus aren’t readily apparent. Courts will be required to question the heritage of EVERY child in order for strangers from a tribal government to step in take custody if they choose.
– Our response: We oppose this stealing of children from their beloved homes and families. There seems to be no regard for the emotional destruction this callous and unwarranted intrusion will cause children and their extended families.

4. If there is any question that a child is Indian – he is to be treated as such until proven otherwise.
– How does one explain this to a child – especially when it is found later that this child was not eligible for membership? The best interest of the child in relation to permanency is irrelevant. Why are the child’s rights and feelings irrelevant? – We oppose this mandate over our families.

5. The BIA claims the tribe has a right to interfere in a family even if the child is not being removed from the home.
– We oppose this intrusive mandate over our families.

6. No one is to question the placement decision of tribal court, because pointing out problems – for example, that a certain home has a history of child abuse – undermines the authority of tribal court.
– Our response: We have documentation of many, many children placed in known danger by tribal courts, with the child victim ending up abused, raped, or even murdered. 3-year-old Ahziya Osceola of Florida, whose body was found stuffed in a box just last month, is case in point. – We oppose this mandate over our families and – for the sake of our children – will continue to question potentially dangerous custody placements made by any entity in any jurisdiction – appealing to media as often as necessary.

 Some tribal governments are reticent to admit they do not have enough safe homes to place children in, and not wanting to place the children off the reservation, they have placed children in questionable homes. (Based on reports from ACF Regional Director Thomas Sullivan and Tribal police officer LaVern Littlewind)
 Abuses are rampant on some reservations because the U.S. Government has set up a system that allows extensive abuse to occur unchecked and without repercussion.
 It has become increasingly apparent that to some in federal government – as well some in tribal government – that it is more important to protect tribal sovereignty than it is to protect our children.

In fact – some are choosing to protect tribal sovereignty at the expense of our children.

If it was not obvious to some in the years leading up to this that the ICWA is more about protecting tribal sovereignty than it is about protecting children, than these BIA rules confirm it.

According to the BIA, the only ‘best interest’ of importance is keeping the child with the tribal government. The BIA rules repeat that Congress has:

“a presumption that ICWA’s placement preferences are in the best interests of Indian children; therefore, an independent analysis of “best interest” would undermine Congress’s findings.”

To paraphrase the above quote, the true best interest of our individual children is irrelevant. Don’t even try to argue it.

This flies in the face of everything we know about child psychology and development, let alone what we know about our own 4-year-old children.

These BIA rules reiterate a prejudicial assumption that everyone with any tribal heritage has exactly the same feelings, thoughts and needs. It prejudicially assumes it is always in the best interest of a child to be under the jurisdiction of tribal government, even if parents and grandparents have chosen and raised them in a different environment with different worldview – and even if the child himself/herself has made it clear what he/she needs and prefers.

Speaking as the birth mother and grandmother of enrollable U.S. citizens, I need our Congressmen to understand that these children are not the tribal government’s children.
They are our children.

The following are a list of proposed ICWA changes CAICW would like to see:

1. Children of tribal heritage should be guaranteed protection equal to that of any other child in the United States.

a) Children should never be moved suddenly from a home that is safe, loved, and where they are emotionally, socially and physically comfortable simply because their caregivers are not of a certain heritage. The best interest of the child should be considered first, above the needs of the tribal community.

b) State health and welfare requirements for foster and adoptive children should apply equally to all. If there is proven evidence of emotional and/or physical neglect, the state has an obligation to that child’s welfare and should be held accountable if the child is knowingly or by Social Service neglect left in unsafe conditions. ( – Title 42 U.S.C 1983)

2. Fit parents, no matter their heritage, have the right to choose healthy guardians or adoptive parents for their children without concern for heritage and superseding wishes of tribal government. US Supreme Court decisions upholding family autonomy under 5th and 14th Amendment due process and equal protection include Meyer vs. Nebraska, Pierce v. Society of Sisters, and Brown v. Board of Education.

3. The “Existing Indian Family Doctrine” must be available to families and children that choose not to live within the reservation system.

a) In re Santos Y, the court found “Application of the ICWA to a child whose only connection with an Indian tribe is a one-quarter genetic contribution does not serve the purpose for which the ICWA was enacted…” Santos y quoted from Bridget R.’s due process and equal protection analysis at length. Santos also states, Congress considered amending the ICWA to preclude application of the “existing Indian family doctrine” but did not do so.”

b) In Bridget R., the court stated, “if the Act applies to children whose families have no significant relationship with Indian tribal culture, such application runs afoul of the Constitution in three ways:

– it impermissibly intrudes upon a power ordinarily reserved to the states,
– it improperly interferes with Indian children’s fundamental due process rights respecting family relationships; and
– on the sole basis of race, it deprives them of equal opportunities to be adopted that are available to non-Indian children and exposes them…to having an existing non-Indian family torn apart through an after the fact assertion of tribal and Indian-parent rights under ICWA”.

c) In re Alexandria Y., the court held that “recognition of the existing Indian family doctrine [was] necessary to avoid serious constitutional flaws in the ICWA” and held that the trial court had acted properly in refusing to apply ICWA “because neither [child] nor [mother] had any significant social, cultural, or political relationship with Indian life; thus, there was no existing Indian family to preserve.”

Question: If current ICWA case law includes many situations where existing Family Doctrine has already been ignored, then have serious constitutional flaws already occurred?

4. United States citizens, no matter their heritage, have a right to fair trials.

a) When summoned to a tribal court, parents and legal guardians, whether enrolled or not, have to be told their rights, including 25 USC Chapter 21 § 1911. (b) “Transfer of proceedings [to tribal jurisdiction] …in the absence of good cause to the contrary, [and] objection by either parent…”

b) The rights of non-member parents must be upheld: for example: 25 USC Chapter 21 § 1903. Definitions “Permanent Placement” (1) (iv) “shall not include a placement based … upon an award, in a divorce proceeding, of custody to one of the parents.

c) Non-members have to be able to serve county and state summons to tribal members within reservation boundaries and must have access to appeal.

d) Under the principles of comity: All Tribes and States shall accord full faith and credit to a child custody order issued by the Tribe or State of initial jurisdiction consistent within the UCCJA – which enforces a child custody determination by a court of another State – unless the order has been vacated, stayed, or modified by a court having jurisdiction to do so under Article 2 of the UCCJA.

5. Adoptive Parents need well-defined protections. These citizens among us have been willing to set aside personal comforts and take in society’s neediest children. Adoptive parents take many risks in doing this, the least of which is finances. People build their lives around family. Adoptive parents risk not only their own hearts, but also the hearts of any birth children they have as well as the hearts of their extended family. These parents have an investment in the families they are building and have a right to know that they can put their names on the adoption paper with confidence. If we, as a society, continue to abuse these parents, we will find fewer people willing to take the risk of adoption and more and more children will languish in foster homes.

6. A “Qualified expert witness” should be someone who is able to advocate for the well-being of the child, first and foremost: a professional person who has substantial education and experience in the area of the professional person’s specialty and significant knowledge of and experience with the child, his family, and the culture, family structure, and child-rearing practices the child has been raised in.

a) There is nothing a tribal social worker inherently knows about a child based on the child’s ethnic heritage. This includes children of 100% heritage who have been raised totally apart from the tribal community. A qualified expert witness needs to be someone who has not only met the child, but has worked with the child, is familiar with and understands the environment the child has thus far been raised in, and has professional experience with some aspect of the child’s emotional, physical or academic health. This is far more important than understanding the customs of a particular tribe.

7. Finally, if tribal membership is a political rather than racial designation, (as argued) than is it constitutional for the definition of an Indian child to include “eligible” children, rather than “enrolled” children?

a) 25 USC Chapter 21 § 1903. Definitions: (4) ”Indian child” means any unmarried person who is under age eighteen and is either

i) member of an Indian tribe or
ii) is eligible for membership in an Indian tribe and is the biological child of a member of an Indian tribe;

However;

1. Tribal governments have been given the right as sovereign entities to determine their own membership at the expense of the rights of any other heritage or culture as well as at the expense of individual rights.

2. ICWA does not give Indian children or their legal guardians the choice whether to accept political membership in the tribe. Legal guardians have the right to make that choice for their children, not governments.

3. Non-member relatives are told these children are now members of an entity with which the family has had no past political, social or cultural relationship.

4. So is it then the blood relationship that determines membership? Bridget R., stated, “If tribal determinations are indeed conclusive for purposes of applying ICWA, and if, … a particular tribe recognizes as members all persons who are biologically descended from historic tribal members, then children who are related by blood to such a tribe may be claimed by the tribe, and thus made subject to the provisions of ICWA, solely on the basis of their biological heritage. Only children who are racially Indians face this possibility.” Isn’t that then an unconstitutional race-based classification?

5. Keeping children, no matter their blood quantum, in what the State would normally determine to be an unfit home on the basis of tribal government claims that European values don’t apply to and are not needed by children of tribal heritage is racist in nature and a denial of the child’s personal right to life, liberty and the pursuit of happiness.

6. Even with significant relationship with Indian tribal culture, forced application of ICWA conflicts with the Constitution in three ways:
(1) It impermissibly intrudes upon a power ordinarily reserved to the states,
(2) It improperly interferes with Indian children’s fundamental due process rights; and
(3) On the sole basis of race, it deprives them of equal opportunities to be adopted that are available to non-Indian children.

We are aware that certain tribal entities and their supporters – those who are in the business of jurisdiction over our children – are adamant that these rules be enforced as written. We realize it would be messy and difficult to defy the demands of tribal governments. We understand that many will not want to do that.

Please understand that we will never stop fighting to protect our children from those who wish to exploit them for profit. Our children are more important than tribal sovereignty.

Thank you for listening to all the stakeholders.

Elizabeth Sharon (Lisa) Morris
Chairwoman
Christian Alliance for Indian Child Welfare (CAICW)
PO Box 460
Hillsboro, ND 58045

Attached:

Tom Sullivan’s 29 Page Whistleblower report (2015, April)

References:

ACF. (2007). Tribal Child Counts. Washington DC: Child Care Bureau, Office of Family Assistance.
Associated Press. (2014, April 28). 42 people killed in homicidal violence in 2013 on country’s largest Indian reservation. Retrieved from: http://www.foxnews.com/us/2014/04/28/42-people-killed-in-homicidal-violence-in-2013-on-country-largest-indian/
Belford, D. (2012). Life with James [Video].
Benedict, J. (2000). Without Reservation. New York: Harper.
CAICW Testimony: CHILD PROTECTION AND THE JUSTICE SYSTEM on the Spirit Lake Reservation: Oversight Hearing before the Subcommittee on Indian and Alaska Native Affairs; COMMITTEE ON NATURAL RESOURCES of the House of Representatives, 113th Congress, (2014, June 24)
CAICW Request. Letter to Senator Tom Coburn, urging Inspector General Investigation, (2014, July 31)
Domestic and Sexual Violence outside the Reservations in North Dakota get lots of attention from the ACF. (September 2013) Email Correspondence between ACF Officials
In re SANTOS Y., B144822 (Cal. App. 4th, Second Dist. Div. Two July 20, 2001).
Jackson, J. C. (1999, February 12). Director of Government Affairs. (U. C. Rights, Interviewer) Retrieved from Jack C. Jackson, Jr., Director of Governmental Affairs, National Congress of American Indians, Statement on the importance of an accurate census to American Indians and Alaska Natives, before the U.S. Commission on Civil Rights, Washington, D.C.,
Karnowski, S. (2013). Feds Say Native Mob Gang Dented but Work Remains. Minneapolis: ABC News.
Kershaw, S. (2006, February 19), Tribal Underworld: Drug Traffickers Find Haven in Shadows of Indian Country, New York Times
Lawrence, William (Bill). (2007). Publisher. Native American Press/Ojibwe News.
LittleWind, LaVern ‘Bundy’. (2014) Audio Tapes between tribal police officer Bundy Littlewind and Spirit Lake Social Services. Retrieved at https://caicw.org/2014/09/25/five-hours-later-he-died-in-a-car-wreck/#.VUo2LSFVjBE
Morris, E. (2007). VIEWPOINT: Law could tear children from a ‘tribe’ they love . Grand Forks: Grand Forks Herald.
Morris, E. (2013) To Better Protect the Children
Morris, Roland John. Testimony before the Senate Committee on Indian Affairs (1998) – Concerning tribal corruption and jurisdiction
Morrison, S.K., (1998), Testimony before the Senate Committee on Indian Affairs on tribal sovereignty and tribal courts, Choctaw Attorney; Wilburton, Oklahoma;
Necessary Corrective Action. (2012, February) BIA Regional Social Worker assessment of changes needed to ensure protection of children at Spirit Lake – sent to BIA Superintendent
Omdahl, L. (2013, July). Commentary by Former ND Lt. Governor. Grand Forks: Grand Forks Herald.
Oversight Hearing. (2014). CHILD PROTECTION AND THE JUSTICE SYSTEM ON THE SPIRIT LAKE INDIAN RESERVATION. Subcommittee on Indian and Alaska Native Affairs; Committee on Natural Resources (p. June 24). Washington DC: HOUSE OF REPRESENTATIVES, 113th Congress.
Quilt. (2004). Child Counts. Warm Spring: NCCIC
Rowley, Sean. (2015, April). ICWA Discussed at Symposium Seminar. Tahlequah Daily Press
Smart, P. M. (2004). In Harm’s Way. The Salt Lake Tribune.
Sullivan, Thomas F., R. A. 12th Mandated Report concerning Suspected Child Abuse on the Spirit Lake Reservation. (2013, February) To ACF Superiors in Washington DC
Sullivan, Thomas F., R. A. 13th Mandated Report concerning Suspected Child Abuse on the Spirit Lake Reservation. (2013, April) To ACF Superiors in Washington DC
Sullivan, Thomas F., R. A. Attempt to go to Spirit Lake, (2013, August) – email correspondence between Tom Sullivan and his DC Superiors
Sullivan, Thomas, R. A. (2014, April 4). Sullivan rebukes his DC Superiors for their negligence of children on Indian reservations. To ACF Superiors in DC. Retrieved from: https://caicw.org/2014/04/04/tom-sullivan-rebukes-his-dc-superiors-for-their-negligence/
Sullivan, Thomas F., R. A. (2014, May 6). Criminal Corruption continues at Spirit Lake. To DC Superiors with the Administration of Children & Families. Retrieved from: https://caicw.org/2014/05/06/criminal-corruption-continues-at-spirit-lake/#.U9cSg7FsLFQ
Sullivan, Tom, R. A. (2014, June 10). Continual Rape of 13-yr-old Ignored. To Superiors at the Administration of Children and Families. Retrieved from:https://caicw.org/2014/06/10/tom-sullivan-continual-rape-of-13-yr-old-ignored/#.U9b7y7FsLFQ
Sullivan, Thomas F., R. A. Response to Chairman McDonald’s Hearing Testimony (2014, June 25) by Thomas Sullivan, Regional Director of the Administration for Children and Families
Sullivan, Thomas F., R. A. Response to ACF Superior Ms. McMullen, (2014, July 1) – by Thomas Sullivan, Regional Director of the Administration for Children and Families
Tevlin, J. (2013, February 12). Tevlin: Sierra shares lessons on Indian adoption. StarTribune.com. Retrieved from: http://www.startribune.com/local/190953261.html?refer=y
Tilus, Michael R., P. M. (2012, March 3). Letter of Grave Concern: Spirit Lake Tribal Social Services Grievances. To Ms. Sue Settle, Chief, Dept. of Human Services, BIA Retrieved from: https://caicw.org/wp-content/uploads/Letter-of-Grave-Concern-Dr.-Tilus-March-3-2012.pdf

NPR ICWA Series Discredited: SD: Indian Foster Care 1: NPR Investigative Storytelling Gone Awry – National Public Radio Ombudsman – August 09, 2013

My finding is that the series was deeply flawed and should not have been aired as it was. Also: S. Dakota Indian Foster Care 2: Abuse In Taking Children From Families?: http://www.npr.org/blogs/ombudsman/2013/08/09/186943868/s-dakota-indian-foster-care-2-abuse-in-taking-children-from-families?ft=1&f= Also: S. Dakota Indian Foster Care 3: Filthy Lucre: http://www.npr.org/blogs/ombudsman/2013/08/09/186943952/s-dakota-indian-foster-care-3-filthy-lucre Also: Indian Foster Care 4: The Mystery Of A Missing $100 Million: http://www.npr.org/blogs/ombudsman/2013/08/09/209282064/s-dakota-indian-foster-care-4-the-mystery-of-a-missing-100-million Also: S. Dakota Indian Foster Care 5: Who Is To Blame For Native Children In White Homes?: http://www.npr.org/blogs/ombudsman/2013/08/09/209528755/s-dakota-indian-foster-care-5-who-is-to-blame-for-native-children-in-white-homes Also: S. Dakota Indian Foster Care 6: Where It All Went Wrong – The Framing: http://www.npr.org/blogs/ombudsman/2013/08/09/203038778/s-dakota-india
Full NPR Ombudsman Report: http://www.scribd.com/doc/159252168/Full-NPR-Ombudsman-Report-South-Dakota-Foster-Care-Investigative-Storytelling-Gone-Awry
http://www.npr.org/blogs/ombudsman/2013/08/09/186943929/s-dakota-indian-foster-care-1-investigative-storytelling-gone-awry