E.  Collateral Attack on Voluntary Placements


25 U.S.C. § 1913(d)
After the entry of a final decree of adoption of an Indian child, the parent may withdraw consent on the grounds that consent was obtained through fraud or duress.  If the court so finds, it shall vacate the decree and return the child to the parent.

25 U.S.C. § 1913(d)
An adoption that has been effective for at least two years, however, may not be invalidated unless otherwise permitted by state law.