In re A.G. CA3

CourtCalifornia Court of Appeal
DecidedApril 3, 2024
DocketC099679
StatusUnpublished

This text of In re A.G. CA3 (In re A.G. CA3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re A.G. CA3, (Cal. Ct. App. 2024).

Opinion

Filed 4/3/24 In re A.G. CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (San Joaquin) ----

In re A.G. et al., Persons Coming Under the Juvenile C099679 Court Law.

SAN JOAQUIN COUNTY HUMAN SERVICES (Super. Ct. No. STK-JD-DP- AGENCY, 2021-0000509)

Plaintiff and Respondent,

v.

M.C.,

Defendant and Appellant.

Appellant M.C., mother of the minors, H.G., A.G., L.G., and E.G., appeals from the juvenile court’s orders terminating parental rights and freeing the minors for adoption. (Welf. & Inst. Code, §§ 366.26, 395; statutory section citations that follow are found in the Welfare and Institutions Code unless otherwise stated.) Mother contends

1 that the juvenile court failed to comply with the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.) by failing to make an ICWA finding prior to terminating parental rights. We will conditionally affirm subject to full compliance with the ICWA on remand, as described in this opinion.

FACTS AND HISTORY OF THE PROCEEDINGS Because the issue on appeal is limited to ICWA compliance, we need not set forth a detailed recitation of the underlying facts and procedure. It is sufficient to say that on December 26, 2021, the San Joaquin County Human Services Agency (Agency) sought a protective custody warrant and thereafter, filed a petition alleging that the newborn minor came within the provision of section 300, subdivision (b)(1), failure to protect, and subdivision (j), abuse of a sibling, based on both mother and the newborn minor, E.G., testing positive for amphetamines at the time of E.G.’s birth. Mother had previously tested positive for amphetamines at the time of L.G.’s birth in June 2020, and she failed to obtain prenatal care during her pregnancy with E.G. The detention report showed that the investigating social worker asked the parents about possible Native American ancestry prior to the filing of the section 300 petition. The Agency filed Indian Child Inquiry Attachment (ICWA-010) forms, reporting a social worker spoke with father, W.G., and mother about whether the minor had any Native American ancestry, and the inquiry gave the social worker no reason to believe the minors were or may be Indian children. At the detention hearing, the minors were ordered detained. Father subsequently provided a Parental Notification of Indian Status (ICWA-020) form, stating he had no Native American ancestry. An ICWA-20 form was not completed by mother. However, at the January 11, 2022, jurisdictional hearing, the juvenile court inquired of each parent about Native American ancestry, and both mother and father denied any such ancestry. Following some amendments to the petition, mother

2 and father submitted on the Agency’s jurisdiction report, and the court found the allegations of the petition true. In a subsequent disposition report, the Agency reported that there was no reason to believe the minors were Indian children as defined by the ICWA. At the dispositional hearing, the court found reasonable efforts were made to prevent or eliminate the need for the removal of the minors and adopted the findings and orders proposed in the Agency’s disposition report. The applicability of the ICWA was not addressed at subsequent proceedings, and the court did not make an ICWA finding. On February 2, 2023, mother filed notice of her intent to file a writ challenging the termination of her reunification services. On April 4, 2023, this court denied mother’s petition for extraordinary writ on the merits. (Joyce G. v. Superior Court (1995) 38 Cal.App.4th 1501, 1513-1514.) The order denying the petition noted that mother’s contention that the ICWA inquiry and notice provisions were not satisfied was premature because the juvenile court had not made a ruling on ICWA at or before the challenged hearing. (In re J.J. (2022) 81 Cal.App.5th 447, 461.) The order noted that any opinion would be advisory and encouraged the juvenile court and the Agency to ensure full compliance with the ICWA as early as possible in the proceedings. On April 6, 2023, the Agency filed an ICWA-020 form completed by mother, stating that she did not have Native American ancestry. The Agency’s April 28, 2023, status review report showed that mother and father both denied having Native American ancestry at the jurisdiction hearing. Additionally, it was reported that on April 13, 2023, the Agency ran a Nexis Lexis search and sent ICWA inquiry letters to maternal and paternal relatives. The report reflected that the maternal grandparents and paternal grandfather were deceased, and that the paternal grandmother had not come forward for visitation. Based on this inquiry, the Agency reported there was no reason to believe the minors were Indian children within the meaning of the ICWA. On August 7, 2023, the Agency filed the ICWA-020 forms completed by the paternal grandmother and paternal aunt, in which they each indicated having no Native

3 American ancestry. In its August 25, 2023, section 366.26 report, the Agency reported that there was no reason to believe the minors were Indian children within the meaning of the ICWA based on its inquiry. On October 9, 2023, at the contested selection and implementation hearing pursuant to section 366.26, the juvenile court did not make any further findings regarding the ICWA, and found the minors adoptable, determined no statutory exceptions to adoption were applicable, and terminated parental rights as to mother and father.

DISCUSSION Mother contends that the juvenile court failed to consider whether the Agency adequately complied with the notice and hearing requirements of the ICWA and failed to make a finding on the applicability of the ICWA. We agree that remand is necessary. As this court recently explained: “ ‘The ICWA protects the interests of Indian children and promotes the stability and security of Indian tribes by establishing minimum standards for removal of Indian children from their families, and by permitting tribal participation in dependency proceedings. [Citations.] A major purpose of the ICWA is to protect “Indian children who are members of or are eligible for membership in an Indian tribe.” [Citation.]’ (In re A.W. (2019) 38 Cal.App.5th 655, 662 [].) The ICWA defines an ‘ “Indian child” ’ as a child who ‘is either (a) a member of an Indian tribe or (b) is eligible for membership in an Indian tribe and is the biological child of a member of an Indian tribe.’ (25 U.S.C. § 1903(4).) The juvenile court and the social services [agency] have an affirmative and continuing duty, beginning at initial contact, to inquire whether a child who is subject to the proceedings is, or may be, an Indian child. (Cal. Rules of Court, rule 5.481(a); § 224.2, subd. (a).)” (In re G.A. (2022) 81 Cal.App.5th 355, 360, review granted Oct. 12, 2022, S276056.) “[S]ection 224.2 creates three distinct duties regarding ICWA in dependency proceedings. First, from the Agency’s initial contact with a minor and his [or her] family,

4 the statute imposes a duty of inquiry to ask all involved persons whether the child may be an Indian child. (§ 224.2, subds.

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Bluebook (online)
In re A.G. CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ag-ca3-calctapp-2024.