The core dispute in the case was over what the ICWA's requirement of taking "active efforts" to provide services before termination means. The Court concluded that it does not require the state to necessarily provide services as to the specific child involved in the case; the mother of JL had been provided services related to her other children before her rights were terminated as to them, and the Court found that these services were sufficient.

The Court declined to impose a bright-line rule regarding when the services have to be provided, opting for a sort of totality of the circumstances test, taking into account when the services were provided, the current state of the parent and the parent's skills, etc., etc.

Justices Cavanagh and Kelly agreed with the test, but disagreed that the state met its burden in JL's case. Justice Cavanagh pointed out that the case workers testified that they had not evaluated the mother for about a year and a half prior to termination, and Cavanagh didn't think that this could satisfy the "active efforts" requirement, even using the more lenient test adopted by the Court.