In re B.O. CA4/2

CourtCalifornia Court of Appeal
DecidedFebruary 20, 2025
DocketE084374
StatusUnpublished

This text of In re B.O. CA4/2 (In re B.O. 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 B.O. CA4/2, (Cal. Ct. App. 2025).

Opinion

Filed 2/20/25 In re B.O. 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 B.O., a Person Coming Under the Juvenile Court Law.

SAN BERNARDINO COUNTY CHILDREN AND FAMILY SERVICES, E084374

Plaintiff and Respondent, (Super.Ct.No. J301307)

v. OPINION

J.G.,

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Cara D. Hutson,

Judge. Affirmed.

Megan Turkat Schirn, under appointment by the Court of Appeal, for Defendant

and Appellant.

Tom Bunton, County Counsel, Kristina M. Robb, Deputy County Counsel for

Plaintiff and Respondent.

1 Defendant and appellant J.G. (Father) appeals from the juvenile court’s

dispositional order in which the court found the Indian Child Welfare Act of 1978

(ICWA; 25 U.S.C. § 1901 et seq.) “may apply” to the child he claims is his son, B.O.

(Minor; born in June 2024). The sole issue Father raises on appeal is plaintiff and

respondent San Bernardino County Children and Family Services (CFS) had not yet—at

the time of the disposition hearing—met its duty of inquiry regarding whether Minor may

be an Indian child, under California law implementing ICWA. (Welf. & Inst. Code,1

§ 224.2, subd. (b).) Specifically, CFS had not yet asked any maternal extended family

members whether Minor might have Indian ancestry. We affirm the court’s order finding

that ICWA may apply.

BACKGROUND

The relevant background is brief. CFS obtained a protective custody warrant

(§ 340) under which it detained Minor soon after he tested positive for fentanyl and

amphetamine at birth. CFS filed a dependency petition on grounds Father and S.O.

(Mother) failed to protect Minor from serious physical harm and Father failed to reunify

with a half-sibling. (§ 300, subds. (b)(1), (j).)

1 All further statutory references are to the Welfare and Institutions Code unless otherwise indicated. We note that, like the Supreme Court, we use the term “Indian” to reflect the statutory language. No disrespect is intended. (In re Dezi C. (2024) 16 Cal.5th 1112, 1125, fn. 1.)

2 During the course of CFS’s investigation, social workers spoke to Minor’s

maternal grandmother (MGM) on more than one occasion, but nothing in the record

indicates she was asked whether Minor might have Indian ancestry. MGM advised the

workers of other relatives to be considered for placement, including, in a separate

household, maternal grandfather “Michael.” MGM provided his and another relative’s

contact information. The record does not suggest CFS inquired of any maternal relatives

regarding the family’s Indian background, if any.

CFS’s report for the combined jurisdiction and disposition hearing indicated its

inquiry was ongoing, recommending in a handwritten interlineation that the juvenile

court find Minor “MAY come under the provisions of the Indian Child Welfare Act.” The

juvenile court adopted this recommendation at the hearing, finding: “ICWA may apply.”

(All caps omitted.) The court also found Minor could not safely be placed in Father’s

care, removed Minor from his and Mother’s legal custody, and declined to order

reunification services for Father—none of which Father challenges on appeal.

DISCUSSION

Father contends CFS failed to meet its duty under governing law to inquire of

extended relatives whether Minor may have Indian ancestry. (§ 224.2, subd. (b)(2).)

CFS does not dispute the duty or that it applies to Minor’s extended maternal relatives

here. CFS instead argues Father’s challenge is not yet ripe and requests dismissal of the

appeal on that basis, citing J.J. v. Superior Court (2022) 81 Cal.App.5th 447 (J.J.).

In J.J., the mother sought an extraordinary writ to overturn the juvenile court’s

orders denying her reunification services (§ 361.5) and setting a hearing to select a

3 permanent plan for her children (§ 366.26). (J.J., supra, 81 Cal.App.5th at p. 450.) The

mother sought writ relief on alternate grounds: (1) insufficient evidence supported the

court’s reunification bypass order, and (2) she alleged inquiry and notice failures under

ICWA. The reviewing court granted the mother relief on the first ground (J.J., at pp. 455-

460, 461-462), and then explained why it did not reach the alternate ground.

In particular, “because the juvenile court made no final ICWA ruling at or before

the challenged dispositional hearing as to whether the ICWA applied to the proceedings,

mother’s claim is premature. That is, ICWA issues are not ripe for review. ‘ “Ripeness”

refers to the requirements of a current controversy.’ [Citation.] An issue is not ripe for

review unless and until it is ‘sufficiently concrete to allow judicial resolution even in the

absence of a precise factual context.’ ” (J.J., supra, 81 Cal.App.5th at p. 461.) Thus, the

J.J. court explained: “Because the dependency case is still ongoing, any perceived

deficiencies with ICWA inquiry and noticing may still be resolved during the normal

course of the ongoing dependency proceedings. Therefore, we decline mother’s

invitation to assess the adequacy of the ICWA inquiry and noticing process that is, based

on our assessment of the record, still ongoing as well.” (Ibid.)

These observations are equally apt here. Nevertheless, the J.J. court did not order

dismissal there, and dismissal of the appeal is not required here, even though Father’s

concerns about dismissal are unfounded.

Father opposes CFS’s request for dismissal based on his concern that “dismissal

will serve as an affirmance” of an erroneous ICWA finding. That concern is misplaced

where Father relies on caselaw in which the juvenile court found “that ICWA does not

4 apply,” and affirmance on appeal would imply “ ‘that social workers had fulfilled their

duty of inquiry,’ ” even if they had not. (In re Dominick D. (2022) 82 Cal.App.5th 560,

567.) No similar concern is implicated here, where the trial court did not find ICWA

inapplicable, but rather that it may apply.

Similarly unfounded is Father’s concern that dismissal might put him at risk of

later being deemed to have forfeited his claim of inadequate inquiry. This concern is

unfounded because the duty of inquiry continues throughout a dependency. Both the

juvenile court and CFS have “an affirmative and continuing duty to inquire” whether a

child subject to a section 300 petition may be an Indian child. (§ 224.2, subd. (a); see In

re Dominic F. (2020) 55 Cal.App.5th 558, 566.) “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.” (Dominic F. at p. 566.) The initial duty includes inquiry

of extended family members. (§ 224.2, subd. (b).) No time limit circumscribes or

absolves the court or CFS of meeting this duty. If the inquiry gives the juvenile court or

social worker “reason to believe that an Indian child is involved” (§ 224.2, subd. (e)), the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

San Bernardino County Children & Family Services v. Kimberly L.
243 Cal. App. 4th 1220 (California Court of Appeal, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
In re B.O. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-bo-ca42-calctapp-2025.