Mississippi Band Of Choctaw Indians v. Holyfield

490 U.S. 30 (1989)

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Nature of the Case

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Facts

Two twin babies were born out of wedlock in 1985. The mother (M) and father (F) were both enrolled members of the Choctaw Indian Tribe (P) and were residents of the Choctaw Reservation in Neshoba County Mississippi. About two weeks after their birth, M executed a consent to adopt form and F signed a similar form. Holyfield filed a petition for adoption, and the chancellor issued a final decree just three weeks later. The final decree made no mention or reference to the ICWA or the children's Indian background. Two months later P moved to vacate the adoption decree on grounds that under the ICWA exclusive jurisdiction was vested in the tribal court. The court held that P never obtained jurisdiction in that the mother went to some lengths to make sure that the children were born outside the reservation and that the parents had arranged for a prompt adoption by the Holyfields and at no time since birth had the children ever resided on the reservation. The Supreme Court of Mississippi affirmed. The Supreme Court granted certiorari.