Comment Jones The Indian Welfare Act Handbook this is one of the sources you have cited a number of times Although the author first states that notwithstanding the clear language of Holyfield repudiating the exception so this source seems to be a little biased in its reading of Holyfield Nevertheless on p 32 of this book in referencing the status of the EIF exception the author notes It is apparent that this area of the law is in a state of flux and practitioners are cautioned to review their state court decisions to determine whether ICWA applies to a particular fact situation The book discusses the Crews decision out of Washington a more recent case and notes that the court cites Holyfield to support the survival of the EIF exception The author also references court rulings from Oklahoma Alabama and South Dakota where the EIF exception is still alive and well following Holyfield Whether the Crews case and cases like it are right or wrong it remains the case that Holyfield is interpreted differently by different jurisdictions and the Supreme Court has not clarified its position