In re T.R. (2023)

Denial of reunification services based on father's alleged infliction of severe physical harm was not supported by evidence when court failed to make required findings on the record and the record was not sufficient to infer basis for court's reasoning; Casting doubt on propriety of implying findings to justify denial of reunification; Severe physical harm bypass to reunification requires proof of an actual injury, not a risk of future injury; ICWA claim for failure to investigate Indian heritage not ripe when dependency case is still ongoing