Mississippi Band of Choctaw Indians v. Holyfield

Unmarried tribal members J.B. and W.J., both enrolled in the Mississippi Band of Choctaw Indians (Tribe) (plaintiff), traveled over 200 miles off the reservation to give birth to twins, whom they then consented to have adopted by the Holyfields (defendants). A chancery court granted the adoption, and when the Tribe moved to vacate it as beyond the court's jurisdiction under the Indian Child Welfare Act (ICWA), the chancery court and the Mississippi Supreme Court both held the Tribe never gained exclusive jurisdiction, reasoning the parents had abandoned the children by relinquishing them for adoption and that the twins' domicile followed the Holyfields, who stood in loco parentis. The U.S. Supreme Court granted certiorari.