In re Avery L. CA2/4

CourtCalifornia Court of Appeal
DecidedJanuary 25, 2024
DocketB327700
StatusUnpublished

This text of In re Avery L. CA2/4 (In re Avery L. CA2/4) 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 Avery L. CA2/4, (Cal. Ct. App. 2024).

Opinion

Filed 1/25/24 In re Avery L. CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION FOUR

In re AVERY L., B327700

a Person Coming Under the Juvenile (Los Angeles County Court Law. Super. Ct. No. 21CCJP02686)

LOS ANGELES COUNTY DEPARTMENT OF CHILDREN AND FAMILY SERVICES,

Plaintiff and Respondent,

v.

S. L.,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Tara Newman, Judge. Affirmed. Jamie A. Moran, by appointment of the Court of Appeal, for Defendant and Appellant. Dawyn R. Harrison, County Counsel, Kim Nemoy, Assistant County Counsel, and William D. Thetford, Principal Deputy County Counsel, for Plaintiff and Respondent. INTRODUCTION S.L. (mother) appeals from the juvenile court’s order terminating parental rights (Welf. & Inst. Code, § 366.26)1 over her child Avery L. (born May 2021). Mother’s sole contention on appeal is that the Los Angeles County Department of Children and Family Services (DCFS) failed to comply with the “initial duty to inquire” under the Indian Child Welfare Act (25 U.S.C. § 1901 et seq.) (ICWA) and related California statutes (§ 224 et seq.). We agree with mother that DCFS failed to conduct a proper initial inquiry into Avery’s Indian ancestry by not interviewing certain extended family members. We conclude, however, that DCFS’s error was harmless. Accordingly, we affirm. The parties are familiar with the facts and procedural history of the case, so we do not restate those details in full here. Below, we discuss only the facts and procedural history germane to the issue on appeal.

DISCUSSION A. Applicable Law and Standard of Review ICWA2 reflects “a congressional determination to protect Indian children and to promote the stability and security of Indian tribes and families by establishing minimum federal standards that a state court . . . must follow before removing an Indian child from his or her family.” (In re Austin J. (2020) 47 Cal.App.5th 870, 881.) Both ICWA and the Welfare and Institutions Code define an “Indian child” as “any unmarried person who is

1 All further statutory references are to the Welfare and Institutions Code unless otherwise stated.

2 Our state Legislature incorporated ICWA’s requirements into California statutory law in 2006. (In re Abbigail A. (2016) 1 Cal.5th 83, 91.)

2 under age eighteen and 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); § 224.1, subds. (a) and (b) [incorporating federal definitions].)3 The juvenile court and DCFS have “an affirmative and continuing duty to inquire whether a child for whom a petition under Section 300 . . . may be or has been filed, is or may be an Indian child.” (§ 224.2, subd. (a); see In re Isaiah W. (2016) 1 Cal.5th 1, 9, 11–12.) This continuing duty can be divided into three phases: the initial duty to inquire, the duty of further inquiry, and the duty to provide formal ICWA notice. The phase at issue here is the initial duty to inquire. The duty to inquire whether a child is an Indian child begins with “the initial contact,” i.e., when the referring party reports child abuse or neglect that triggers DCFS’s investigation. (§ 224.2, subd. (a).) DCFS’s initial duty to inquire includes asking the child, parents, legal guardian, extended family members, and others who have an interest in the child whether the child is, or may be, an Indian child. (Id., subd. (b).) Similarly, the juvenile court must inquire at each parent’s first appearance whether he or she “knows or has reason to know that the child is an Indian child.” (Id., subd. (c).) The juvenile court must also require each parent to complete the parental notification of Indian status form (ICWA-020). (Cal. Rules of Court, rule 5.481(a)(2)(C).) The parties are instructed to inform the court “if they subsequently receive information that provides reason to know the child is an Indian child.” (25 C.F.R. § 23.107(a); § 224.2, subd. (c).)

3 “[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.)

3 Here, the juvenile court found ICWA did not apply, stating “[t]he [c]ourt does not have reason to know that [Avery] is an Indian [c]hild, as defined under ICWA.” We review the court’s ICWA finding for substantial evidence. (In re Josiah T. (2021) 71 Cal.App.5th 388, 401; In re S.R. (2021) 64 Cal.App.5th 303, 312.)

B. Initial Inquiry Mother contends DCFS did not fulfill its initial duty to inquire because DCFS did not ask Avery’s aunts and uncles whether Avery had Indian ancestry.4 We agree. As discussed, section 224.2, subdivision (b) imposes on DCFS a duty of initial inquiry, which includes asking “extended family members” whether the child may be an Indian child. “Extended family members” are defined as the “child’s grandparent, aunt or uncle, brother or sister, brother-in-law or sister-in-law, niece or nephew, first or second cousin, or stepparent.” (See 25 U.S.C. § 1903(2) and § 224.1, subd. (c).) Mother and A.J.S. (father)5 each told DCFS that they had siblings, but there is no evidence DCFS contacted Avery’s aunts or uncles about whether Avery may be an Indian child. DCFS concedes that it erred in failing to contact these extended family members. We, therefore, conclude that DCFS did not conduct a proper initial inquiry. Based on our conclusion, we must next determine whether the error was harmless.

4 Mother also contends DCFS should have attempted to locate “other extended family members in Rhode Island,” but does not identify any relatives other than the aunts and uncles. (See In re D.S. (2020) 46 Cal.App.5th 1041, 1053 [ICWA does not require DCFS to “‘cast about’ for information or pursue unproductive investigative leads”].) 5 Father is not a party to this appeal.

4 C. Harmless Error “Where, as here, there is no doubt that [DCFS’s] inquiry was erroneous, our examination as to whether substantial evidence supports the juvenile court’s ICWA finding ends up turning on whether that error by the Department was harmless—in other words, we must assess whether it is reasonably probable that the juvenile court would have made the same ICWA finding had the inquiry been done properly. [Citation.] If so, the error is harmless and we should affirm; otherwise, we must send it back for the Department to conduct a more comprehensive inquiry.” (In re Dezi C. (2022) 79 Cal.App.5th 769, 777 (Dezi C.), review granted Sept. 21, 2022, S275578.) California appellate courts have crafted several different tests for deciding whether a defective initial inquiry is harmless. (Dezi C., supra, 79 Cal.App.th at pp. 777–782.) Unless and until our Supreme Court weighs in on the matter, we will apply the rule set forth in Dezi C.

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Bluebook (online)
In re Avery L. CA2/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-avery-l-ca24-calctapp-2024.