In re A.V. CA4/2

CourtCalifornia Court of Appeal
DecidedOctober 2, 2023
DocketE080819
StatusUnpublished

This text of In re A.V. CA4/2 (In re A.V. CA4/2) 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.V. CA4/2, (Cal. Ct. App. 2023).

Opinion

See Concurring and Dissenting Opinion

Filed 10/2/23 In re A.V. CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FOURTH APPELLATE DISTRICT

DIVISION TWO

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

RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, E080819

Plaintiff and Respondent, (Super.Ct.No. RIJ2000189)

v. OPINION

M.R., et al.,

Defendants and Appellants.

APPEAL from the Superior Court of Riverside County. Mona M. Nemat, Judge.

Conditionally affirmed and remanded with directions.

Suzanne Davidson, under appointment by the Court of Appeal, for Defendant and

Appellant M.R.

Law Office of Melissa A. Chaitin and Melissa A. Chaitin, under appointment by

the Court of Appeal, for Defendant and Appellant J.V. Minh C. Tran, County Counsel, Teresa K.B. Beecham and Catherine E. Rupp,

Deputy County Counsel for Plaintiff and Respondent.

In this appeal following the termination of parental rights, defendants and

appellants M.R. (mother) and J.V. (father) contend that (1) the juvenile court abused its

discretion by denying mother’s pre-termination petition under Welfare and Institutions 1 Code section 388, which requested additional reunification services based on changed

circumstances, and (2) the county welfare department failed to comply with California

law implementing the Indian Child Welfare Act of 1978 (25 U.S.C. § 1901 et seq.;

ICWA) by failing to ask several available extended family members whether the children 2 have any Indian ancestry. The department contends that the juvenile court “properly

utilized its discretion” in denying mother’s section 388 petition. Regarding ICWA

compliance, the department contends in the alternative that (1) under In re Robert F.

(2023) 90 Cal.App.5th 492, review granted July 26, 2023, S279743 (Robert F.) and In re

Ja.O. (2023) 91 Cal.App.5th 672, 680-681, review granted July 26, 2023, S280572

(Ja.O), it had no duty to ask extended family members about possible Indian ancestry; (2)

it satisfied its duty by conducting a reasonable inquiry; and (3) any error was harmless.

1 Undesignated statutory references are to the Welfare and Institutions Code. 2 “[B]ecause ICWA uses the term ‘Indian,’ we do the same for consistency, even though we recognize that other terms, such as ‘Native American’ or ‘indigenous,’ are preferred by many.” (In re Benjamin M. (2021) 70 Cal.App.5th 735, 739, fn. 1 (Benjamin M.).)

2 We find no abuse of discretion in the denial of mother’s section 388 petition.

Absent further instruction from our Supreme Court, we reject the Department’s

arguments based on Robert F. and Ja.O. because we disagree with those cases’

interpretation of the relevant statutes. We find the analysis of In re Delila D. (2023) 93

Cal.App.5th 953, (Delila D.) more persuasive. We disagree with the department that it

conducted a sufficient inquiry, as it failed to ask several available extended family

members about possible Indian ancestry. We also disagree with the department that the

error was harmless, as the record indicates that there was “readily obtainable information

that was likely to bear meaningfully upon whether the child is an Indian child.”

(Benjamin M., supra, 70 Cal.App.5th at p. 744.) We therefore conditionally affirm and

remand with directions.

I. BACKGROUND

Mother and father are the parents of A.V. (born August 2018), I.V. (born 3 September 2019), J.V. (born October 2020), and X.V. (born August 2022). Parental

rights as to the three older children, but not the youngest, are at issue in this appeal.

In March 2020, plaintiff and respondent Riverside County Department of Public

Social Services (the department) filed a dependency petition alleging that A.V. and I.V.

came within section 300, subdivision (b)(1) (failure to protect) due to mother’s

unresolved substance abuse history and father’s failure to protect. Both A.V. and I.V.

3 Mother (born April 2000) was a minor herself when she became pregnant with her oldest child. Father is about two years older.

3 had tested positive for methamphetamines at birth. Attempts to address the department’s

concerns under a voluntary family maintenance plan had been unsuccessful. Several

times, mother got clean and started participating in services, but each time she relapsed

after a few months.

At the jurisdiction/disposition hearing in July 2020, father reported that he was no

longer in a relationship with mother. The juvenile court sustained the dependency

petition and removed A.V. and I.V. from mother’s custody, but not father’s. The court

ordered reunification services for mother and family maintenance services for father.

In October 2020, the department obtained protective custody warrants to remove

A.V., I.V., and their newborn sibling J.V. from parental custody. Mother and J.V. had

both tested positive for drugs when J.V. was born, and mother admitted to “consistent

use” of methamphetamine during the pregnancy, though she denied it was “daily use.”

The department placed A.V. and I.V. with a maternal great aunt, while J.V. was placed

with a foster family. In supplemental dependency petitions (§ 387) filed a few days later,

the department alleged A.V. and I.V.’s placement with father had not been effective in

protecting them, as father did not participate in services and was allowing mother to

reside in the home and supervise the children. A dependency petition filed as to J.V.

alleged that he came within section 300, subdivisions (b)(1) (failure to protect) and (j)

(abuse of sibling) because of mother’s substance abuse and father’s failure to protect.

The juvenile court ordered all three children detained from both parents.

4 At the January 2021 jurisdiction and disposition hearing, the court sustained the

allegations of the petitions, removed all three children from both parents, and ordered the

parents to participate in reunification services.

Reunification efforts were unsuccessful. The court terminated mother’s services

in August 2021. She had participated in some services and achieved several periods of

demonstrated sobriety, testing negative from February 3 until May 20, and again from

June 10 to July 22. Nevertheless, she had also relapsed and tested positive on May 20

and June 4, and she was terminated from her substance abuse program on July 26 for

missed drug testing and excessive absences. Her visitation with the children was

inconsistent, and when visits did take place her interactions with the children were

unsatisfactory in several respects. Specifically, the social worker observed that mother

(and father) “were unable to properly divide their time” between the children and “would

focus exclusively on one while ignoring the others.” Also, the social worker opined that

the parents relied too heavily on help from others attending the visitation. The parents

“did not seem to understand” when the social worker encouraged them to “use the visit to

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In re A.V. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-av-ca42-calctapp-2023.