Cited by

Sec., ¶ 21 (2009) (“Because the [L]egislature is empowered to set burdens of proof as a matter of substantive law, a valid statute specifying the burden of proof prevails over common law or court rules adopting a different standard.”); Seisinger, 220 Ariz. at 93 ¶ 30.

Sec., ¶ 3 (2009); see also Yvonne L. v. Ariz. Dep’t of Econ.

Sec., -35, ¶ 14 (2009); Ariz. R.P.

Sec., ¶ 9 (2009), and prove by a preponderance of the evidence that the termination is in the child’s best interests.

Sec., ¶ 3 (2009) (citing 25 U.S.C.

that ICWA allows state legislatures to “specify the standard of proof for state-law findings distinct from the findings required by ICWA,” and Arizona’s Legislature has established the standard of proof as beyond a reasonable doubt, ¶¶ 18– 19 (2009); see also Jennifer B. v. Ariz. Dep’t of Econ.

Sec., ¶ 9 (2009) (citing A.R.S.

Sec., ¶ 9 (2009) (citing A.R.S.

Sec., –35, ¶¶ 11, 14 (2009).

Sec., (discussing interrelationship between ICWA and Arizona law for termination of parental rights).

Sec., -35, ¶¶ 11, 14 (2009).

Sec., -35, ¶¶ 14, 16 (2009) ("[Congress] recognized that federal requirements would be in addition to state law requirements, which will themselves prevail over federal law if they are more protective of parental rights."); see also 25 U.S.C.

Sec., ¶ 3, (quoting 25 U.S.C.