In re J.C. CA4/2

CourtCalifornia Court of Appeal
DecidedMay 16, 2023
DocketE080340
StatusUnpublished

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

Opinion

Filed 5/16/23 In re J.C. CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 J.C. et al., Persons Coming Under the Juvenile Court Law.

RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, E080340

Plaintiff and Respondent, (Super.Ct.No. RIJ1700505)

v. OPINION

J.C.,

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. Kelly L. Hansen, Judge.

Conditionally reversed and remanded with directions.

Donna P. Chirco, under appointment by the Court of Appeal, for Defendant and

Appellant.

Minh C. Tran, County Counsel, Julie K. Jarvi, Deputy County Counsel, for

Plaintiff and Respondent.

1 J.C. (Mother) appeals from the juvenile court’s order terminating parental rights to

three of her children. She argues that the court and the Riverside County Department of

Public Social Services (DPSS) failed to comply with state law implementing the Indian

Child Welfare Act of 1978 (ICWA) (25 U.S.C. § 1901 et seq.). We conditionally reverse

the order terminating parental rights and remand for further proceedings.

BACKGROUND

I. Detention, Jurisdiction and Disposition, and Termination of Parental Rights

Mother has seven children. J.I.C., J.L.C., and J.M.C. are the subjects of this

appeal. In November 2021, DPSS received a referral alleging physical abuse of the

oldest sibling, 15-year-old Ja.C. Ja.C. was at the hospital, where a forensic medical exam

revealed significant injuries reportedly caused by Mother. The child had six to seven

fractured ribs, fractures on his sternum, and fresh wounds on his back and arms inflicted

by a vacuum cord.

A law enforcement officer at the hospital advised the social worker that he would

be arresting Mother. The social worker accompanied the officer to Mother’s home,

where the officer arrested Mother for physical abuse of Ja.C. Mother could not identify

any temporary caregivers for the children, and the social worker took temporary custody

of all seven of them.

DPSS filed a petition alleging that the children fell within subdivisions (a), (b),

(g), and (j) of Welfare and Institutions Code section 300. (Unlabeled statutory citations

2 refer to this code.) A few days later, the court detained the children from Mother. At the

time, J.I.C. was three years old, J.L.C. was 10 years old, and J.M.C. was 13 years old.

DPSS’s investigation revealed that Mother had physically abused all seven

children, although Ja.C. suffered the most severe physical abuse. In April 2022, the court

found the allegations of the fourth amended petition to be true and took jurisdiction over

the children. The court found that DPSS had conducted a sufficient ICWA inquiry and

that ICWA did not apply.

With respect to two of the seven children, the court granted their father sole legal

and physical custody and terminated jurisdiction over them. The court adjudged the

remaining five children dependents of the court, removed them from the custody of

Mother and their respective fathers, and denied the parents reunification services. The

court denied reunification services for the fathers of J.L.C. and J.M.C. because the

fathers’ whereabouts were unknown. (§ 361.5, subd. (b)(1).) J.I.C.’s father had appeared

in the case, but the court denied him reunification services for other reasons. (See

§ 361.5, subds. (b)(10), (e)(1).)

The section 366.26 hearing as to J.I.C., J.L.C., and J.M.C. occurred in December

2022.1 The court found that the three children were likely to be adopted and terminated

1 The court did not hold a section 366.26 hearing with respect to Ja.C. and the other remaining member of the sibling group. Ja.C. had been found gravely disabled by a mental health disorder, and a conservatorship had been ordered under the Lanterman- Petris-Short Act (§ 5000 et seq.). He was receiving treatment at a residential psychiatric facility. The other sibling had been detained several times for evaluation and treatment under section 5150, and the child was placed in a short-term residential therapeutic program.

3 parental rights. Although the court did not make an express ICWA finding, the order

terminating parental rights “was ‘necessarily premised on a current finding by the

juvenile court’” that ICWA did not apply to the children. (In re Benjamin M. (2021) 70

Cal.App.5th 735, 740 (Benjamin M.).)

II. ICWA-Related Background

The record does not contain ICWA-020 forms (Parental Notification of Indian

Status) for the parents.2 According to the detention report, the children were the subject

of a dependency case in 2017 and 2018. The juvenile court found in that prior case (in

August 2018) that ICWA did not apply to the children. The detention report contained no

indication that the social worker asked Mother about the children’s Indian status in this

case. DPSS could not locate the fathers of J.I.C., J.L.C., and J.M.C., so the social worker

did not ask them about the children’s Indian status either. The ICWA-010(A) forms

(Indian Child Inquiry Attachment) attached to the petition appeared to rely on the ICWA

inquiry conducted in the prior case. The forms indicated that the social worker was

“advised by [the] Prior Dependency Court Case” that Mother had been questioned about

the children’s Indian status. On the basis of that earlier inquiry, the social worker

checked the box indicating that she had reason to believe the children are or may be

Indian children. The ICWA-010(A) forms identified the Cherokee Nation as the relevant

tribe.

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.” (Benjamin M., supra, 70 Cal.App.5th at p. 739, fn. 1.)

4 The jurisdiction/disposition report contained additional information about the

ICWA findings in the prior dependency case: The juvenile court found in June 2018 that

J.I.C. may be an Indian child, but the court concluded that ICWA did not apply because

the child was placed in Mother’s home. The social worker also reported that in the

present case she recently tried to ask Mother about the children’s Indian status and could

not; Mother was jailed and unavailable for visitation. DPSS had found J.I.C.’s father,

who was incarcerated, and the social worker mailed him a letter asking him to contact her

to discuss the proceedings. Shortly before the jurisdiction and disposition hearing, the

social worker mailed him another letter. She reportedly received no response.

Mother was present at the detention hearing and several other hearings, and the

court did not ask her about the Indian status of the children. J.I.C.’s father was present by

phone for several hearings, and the court did not ask him about the child’s Indian status

either. DPSS had contact with J.I.C.’s paternal grandmother and paternal uncle about

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Bluebook (online)
In re J.C. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jc-ca42-calctapp-2023.