The court's opinion determined that “an Indian biological father could abandon his child in the womb and refuse any support for the birth mother, perhaps contributing to the mother's decision to place the child for adoption – and then he could play his ICWA trump card at the eleventh hour to ignore the mother's decision and the child's best interests.” Brown, nor his family, made an effort to be a part of the child's life before the adoptive couple filed the paperwork; therefore, the destruction of an Indian family would not be relevant in the decision-making process