In re E.D. CA4/2

CourtCalifornia Court of Appeal
DecidedOctober 28, 2025
DocketE086197
StatusUnpublished

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

Opinion

Filed 10/28/25 In re E.D. 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 E.D., a Person Coming Under the Juvenile Court Law.

RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, E086197

Plaintiff and Respondent, (Super.Ct.No. RIJ2100411)

v. OPINION

M.P.,

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. Walter H. Kubelun,

Judge. Affirmed.

Joseph T. Tavano, under appointment by the Court of Appeal, for Defendant and

Appellant.

Minh C. Tran, County Counsel, Teresa K.B. Beecham and Prabhath Shettigar,

Deputy County Counsel, for Plaintiff and Respondent.

1 In this dependency case concerning Minor (Minor), the juvenile court terminated

the parental rights of his mother, defendant and appellant M.P. (Mother), and his alleged

father, E.D.1. (Father). (Welf. & Inst. Code, § 366.26, subd. (b)(1).)1 Mother contends

the juvenile court erred in finding plaintiff and respondent Riverside County

Department of Public Social Services (the Department) conducted an adequate inquiry

into whether Minor may have Indian ancestry. Specifically, Mother asserts the inquiry

was insufficient because the Department did not question Minor’s maternal

grandparents, paternal grandfather, and paternal aunt. We affirm.

FACTS

A. HALF-SIBLINGS

Mother gave birth to two children who are older than Minor—V.P. and S.C

(Siblings). Siblings do not have the same father as Minor. The three children’s

maternal grandmother is an alcoholic. Mother abuses methamphetamine.

Siblings’ dependency case began in 2021. As to Siblings, the juvenile court

found that the Indian Children Welfare Act of 1978 (ICWA) did not apply. Mother did

not participate in her reunification services pertaining to Siblings and therefore did not

reunify with Siblings.

1 All subsequent statutory references will be to the Welfare and Institutions Code unless otherwise indicated.

2 B. DETENTION

Mother gave birth to Minor in October 2023. The Department was immediately

involved with Minor due to Mother’s ongoing dependency case with Siblings. On

October 11, 2023, when speaking with the Department social worker at the hospital,

Mother denied having Indian ancestry and declined to provide Minor’s maternal

grandparents’ contact information. On October 26, 2023, a Department social worker

asked Mother “for any possible family members to consider for placement. [Mother]

abruptly ended the call by hanging up.” The Department detained Minor upon his

discharge from the hospital.

Father did not sign Minor’s birth certificate because Father “was not present at

the time of signing.” Father did not attend the detention hearing. The juvenile court

identified Father as Minor’s alleged father and denied him reunification services.

C. JURISDICTION AND DISPOSITION

Father did not attend the January 2024 jurisdiction hearing. At the hearing, the

juvenile court found ICWA did not apply. The juvenile court again identified Father as

Minor’s alleged father and denied him reunification services.

D. SIX-MONTH REVIEW

In April 2024, Father denied having Indian ancestry. In July 2024, at the six-

month review hearing, the juvenile court found the Department conducted an adequate

ICWA inquiry and Minor is not an Indian child. The juvenile court terminated

Mother’s reunification services.

3 E. TERMINATION OF PARENTAL RIGHTS

In January 2025, a Department social worker again asked Mother about any

Indian ancestry she may have. Mother again denied having Indian ancestry. The social

worker tried telephoning Father to again inquire about any Indian ancestry, but Father’s

telephone number was not in service. The social worker spoke with Minor’s paternal

grandmother who denied having Indian ancestry. The paternal grandmother said that

she and Minor’s paternal grandfather “are of Mexican descent.” The paternal

grandmother also informed the social worker that Father was in prison. The social

worker mailed Father a letter, in prison, inquiring about any Indian ancestry. There is

no indication that Father responded to the letter. The juvenile court terminated

Mother’s and Father’s parental rights to Minor. When terminating Father’s parental

rights, the juvenile court again identified Father as Minor’s alleged father.

DISCUSSION

Mother contends the juvenile court erred in finding the ICWA inquiry was

sufficient because the Department did not question Minor’s maternal grandparents,

paternal grandfather, and paternal aunt about possible Indian ancestry.

We apply the abuse of discretion standard of review. (In re K.H. (2022) 84

Cal.App.5th 566, 589; see also In re Kenneth D. (2024) 16 Cal.5th 1087, 1101-1102.)

“The juvenile court may find that ICWA does not apply to a proceeding if it determines

‘that proper and adequate further inquiry and due diligence as required . . . have been

conducted and there is no reason to know whether the child is an Indian child.’ ” (K.H.,

at p. 589.) When a county places a child in foster care, the county “has a duty to inquire

4 whether that child is an Indian child. Inquiry includes, but is not limited to, asking the

child, parents, . . . [and] extended family members, . . . whether the child is, or may be,

an Indian child.” (§ 224.2, subd. (b)(2).)

Under ICWA, “ ‘parent’ means any biological parent or parents of an Indian

child . . . who has lawfully adopted an Indian child . . . . It does not include the unwed

father where paternity has not been acknowledged or established.” (25 U.S.C.

§ 1903(9).) “A man who may be the father of a child but has not established his

biological paternity, or achieved presumed father status, is an alleged father.” (In re

H.R. (2016) 245 Cal.App.4th 1277, 1283.) Thus, ICWA does not apply to alleged

fathers because they have not established biological paternity. (In re E.G. (2009) 170

Cal.App.4th 1530, 1533.) Because Father is an alleged father, ICWA does not apply to

him or his relatives, as there is no evidence of them having a biological or adoptive

connection to Minor. Consequently, there was no requirement that the Department

inquire of Father or his relatives regarding Indian ancestry.

Father contends, “Father is a person who has an interest in [Minor], was

reasonably available to help the Department with its investigation into whether [Minor]

had any potential Indian ancestry, and thus, he should have been asked about Native

American ancestry.” In April 2024, Father denied having Indian ancestry. In January

2025, a Department social worker tried telephoning Father to again inquire about any

Indian ancestry, but Father’s telephone number was not in service. The social worker

spoke with Minor’s paternal grandmother who denied having Indian ancestry. The

paternal grandmother also informed the social worker that Father was in prison. The

5 social worker mailed Father a letter, in prison, inquiring about any Indian ancestry. The

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Related

Los Angeles County Department of Children & Family Services v. E.C.
245 Cal. App. 4th 1277 (California Court of Appeal, 2016)

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In re E.D. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ed-ca42-calctapp-2025.