H.  Burden of Proof/Necessary Findings


25 U.S.C. § 1912(d)
Before placing an Indian child in foster care or terminating parental rights, the party seeking the placement or termination must satisfy the court that active efforts were made to provide remedial services and rehabilitative programs designed to prevent the breakup of the Indian family and those efforts have proved to be unsuccessful. 

People In Interest of R.L., 961 P.2d 606 (Colo. App. 1998)
Colorado law holds the court must make this finding using the beyond a reasonable doubt standard.

25 U.S.C. § 1912(e)
The court may not order foster care placement without determining that the continued custody of the child by the parent or Indian custodian is likely to result in serious emotional or physical damage to the child. The order must be supported by clear and convincing evidence, and the testimony of a qualified expert witness.

Guidelines for State Courts: Indian Child Custody Proceedings, 44 Fed. Reg. 67584, 67593 D.3(c)
Evidence that shows only the existence of community or family poverty, crowded or inadequate housing, alcohol abuse or nonconforming social behavior does not constitute clear and convincing evidence the continued custody is likely to result in serious emotional or physical damage to the child.

25 U.S.C. § 1912(f)
Before entering an order terminating parental rights, the court must determine that the continued custody of the child by the parent or Indian custodian is likely to result in serious emotional or physical damage to the child. The order must be supported by evidence beyond a reasonable doubt, and the testimony of a qualified expert witness.

People in Interest of L.O.L., 197 P.3d 291 (Colo. App. 2008)
The higher burden of proof to place a child in foster care and to terminate parental rights apply only if the court has found the child to be an Indian child.