25 U.S.C. § 1914
Section 1914 · Petition to court of competent jurisdiction to invalidate action upon showing of certain violations
This is § 104 of the Indian Child Welfare Act of 1978
Amended 1 time on record
Applied in 264 court decisions — leading case Mississippi Band of Choctaw Indians v. Holyfield (1989)
Most recently applied in 347 Or. App. 425 - Dept. of Human Services v. K. C. W. (February 2026)
Cases citing this section usually also cite 25 U.S.C. § 1912 · 25 U.S.C. § 1903 · 25 U.S.C. § 1901
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Any Indian child who is the subject of any action for foster care placement or termination of parental rights under State law, any parent or Indian custodian from whose custody such child was removed, and the Indian child's tribe may petition any court of competent jurisdiction to invalidate such action upon a showing that such action violated any provision of sections 1911, 1912, and 1913 of this title.