In re D.H. CA3

CourtCalifornia Court of Appeal
DecidedAugust 18, 2025
DocketC102928
StatusUnpublished

This text of In re D.H. CA3 (In re D.H. 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 D.H. CA3, (Cal. Ct. App. 2025).

Opinion

Filed 8/18/25 In re D.H. CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 D.H., a Person Coming Under the Juvenile C102928 Court Law.

SAN JOAQUIN COUNTY (Super. Ct. No. STK-JD-DP- HUMAN SERVICES AGENCY, 2023-0000483) Plaintiff and Respondent,

v.

D.H. et al., Defendants and Appellants.

Appellants S.R. (mother) and D.H. III (father) (collectively, parents) appeal1 from the juvenile court’s orders terminating parental rights and freeing D.H. IV (minor) for adoption. (Welf. & Inst. Code,2 §§ 366.26, 395.) Parents contend: (1) the juvenile court

1 Parents filed separate notices of appeal and briefs but join in each other’s arguments. (Cal. Rules of Court, rule 8.200(a)(5).) Further undesignated rule references are to the California Rules of Court. 2 Further undesignated section references are to the Welfare and Institutions Code.

1 erred in denying the petition of his paternal great-great-aunt, Betty C.,3 for placement (§§ 361.3, 388); and (2) this court should conditionally reverse the orders for failure to comply with the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1902 et seq.). We conclude that parents lack standing to appeal the juvenile court’s decision not to place the minor with Betty C. We conditionally reverse the juvenile court’s dispositional orders and finding that ICWA does not apply and will remand to the juvenile court for the limited purpose of further compliance with the inquiry and notice requirements of ICWA and related law. FACTUAL AND PROCEDURAL BACKGROUND On December 21, 2023, the San Joaquin County Human Services Agency (the Agency or Agency) filed a section 300 petition, alleging the minor, born in December 2023, came within section 300, subdivision (b)(1). The petition alleged mother had a history of substance abuse and had tested positive for amphetamines at prenatal appointments and reported using methamphetamine throughout her pregnancy. Mother had seven prior cases involving four half-siblings of the minor in which she failed to reunify, and parents had an open case in Nevada for minor’s sibling, Da. H., who was placed with a paternal great-great-aunt in Nevada. Father also had a history of substance abuse and had failed or refused to rehabilitate. Additionally, the parents lacked a safe, stable residence. As recounted in the petition, a social worker interviewed the minor’s parents in the hospital. Mother reported no Native American ancestry, but father reported his grandmother was a registered member of an unknown tribe in Oklahoma. Both mother

3 To protect their privacy, we refer to the witnesses by their first name and last initial or initials. (Rule 8.90(b)(10) & (11).) Betty C., is referred to in the record numerous times as father’s “great-aunt.” In her testimony at the child placement hearing in November 2024, Betty C. clarified that she is father’s great-great-aunt. We will refer to father’s relative as Betty C. or his great-great-aunt.

2 and father completed Parent Notification of Indian Status forms ICWA-020. Mother checked a box disclaiming any Indian tribe connection, but father checked the box that the minor is or may be a member of, or eligible for membership in, a federally recognized Indian tribe. On the line for the name of the tribe, father wrote: “Unknown in Oklahoma father’s grandmother.” The Agency concluded there was a claim of Native American heritage, but not sufficient information for “ ‘reason to know’ ” the minor is ICWA eligible. The Agency stated that notice would be provided to all federally recognized Indian tribes and the Bureau of Indian Affairs (BIA). In the interview, the parents stated that the minor’s sibling, Da. H., was two years old as of December 21, 2023, and lived with a parental great-great-aunt in Las Vegas, Nevada. Mother initially claimed she lived at a residence in Stockton but later admitted she was homeless. Father denied he was homeless, but the social worker was unable to verify father’s claim that he lived with his adult daughter, Tiffany L. The social worker met with the minor’s assigned nurse at the hospital, who reported speaking by telephone with Betty C. According to Betty C., the parents were homeless and lived in a tent along the railroad tracks in Stockton. Parents asked for Tiffany L. to be assessed for emergency relative placement, and, if the minor could not be placed with Tiffany L., they requested an Interstate Compact on Placement of Children (ICPC) assessment for Betty C. in Las Vegas, Nevada.4 An assessment of Tiffany L. determined that she had a disqualifying criminal history.

4 The ICPC (Fam. Code, § 7900 et seq.) governs conditions for out-of-state placement of dependent children. (In re Z.K. (2011) 201 Cal.App.4th 51, 66.) “Among other things, the ICPC provides that a dependent child subject to the compact’s provisions ‘shall not be sent, brought, or caused to be sent or brought into the receiving state until the appropriate public authorities in the receiving state shall notify the sending agency, in writing, to the effect that the proposed placement does not appear to be contrary to the interests of the child.’ (Fam. Code, § 7901, art. 3, subd. (d).)” (Id. at p. 58, fn. 4.)

3 The next day, the social worker spoke with Betty C. Betty C. reported she had five other children in her home in addition to Da. H. She received support from her husband, Ralph C., an attorney from Stockton, in caring for the minor children in her home. On December 29, 2023, Betty C. and Ralph C. requested placement of the minor with them. They stated they had placement of the minor’s sibling, Da. H., and would like to keep the children together. On January 4, 2024, the juvenile court authorized the Agency to start the ICPC process but stated that the minor should not yet be moved. At the hearing, the juvenile court also questioned both mother and father regarding possible Native American heritage. Mother stated she had no Native American heritage, and father said, “I don’t know.” On January 12, 2024, the Agency filed a jurisdictional and disposition report recommending bypass of reunification services for mother and father under sections 361.5, subdivisions (b)(10), (11), and (12). The report repeated father’s claim that his grandmother was a registered member of an unknown tribe in Oklahoma. Father was interviewed regarding his family background. He stated his father died 15 to 20 years ago, and he had not talked to his mother in approximately nine years. Father had four living siblings, twins S.H. and Sa. H. in Oakland, California, and M. H. and A. R. The Agency sent placement letters to a number of mother’s potential family members, as well as Sa. H., father’s half-sibling Dal. H., and father’s current wife V. H. The Agency noted Betty C. and Ralph C.’s request for placement of the minor but observed that the minor’s relationship with Da. H. was “nonexistent” as she was in foster care in another state and had never met him. The Agency acknowledged it was appropriate to develop and maintain the sibling relationship, but the ICPC process needed to be completed. On January 30, 2024, the minor was made a dependent child of the juvenile court. The court authorized the Agency to make an appropriate placement of the minor.

4 On February 1, 2024, the Agency served a Notice of Child Custody Proceeding for Indian Child (ICWA-030) on the BIA. No tribe was specified.

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Bluebook (online)
In re D.H. CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-dh-ca3-calctapp-2025.