The Indian Child Welfare Act (ICWA) was enacted to address a history of “wholesale removal of Indian children from their homes.” It places minimum federal standards on state proceedings involving an Indian child. In this case, Colorado sought to terminate the parental rights of an Indian mother whose child had significant special needs. During the proceedings, the Department of Human Services changed course from seeking termination, to seeking placement with extended family. The trial court terminated parental rights, granted the Department guardianship, but precluded placement with extended family. The court of appeals affirmed termination, finding the Department used “active efforts” to rehabilitate mother, which failed. But, the trial court erroneously deviated from the ICWA’s placement preferences, thus, Department could place the child with extended family.