In re J.N. CA4/2

California Court of Appeal·Decided June 5, 2026·No. E086948·Unpublished

Opinion

Filed 6/5/26 In re J.N. 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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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.N. et al., Persons Coming Under the Juvenile Court Law.

SAN BERNARDINO COUNTY CHILDREN AND FAMILY SERVICES, E086948

Plaintiff and Respondent, (Super.Ct.Nos. J277532 & J277533 & J277534 & J277535) v. OPINION M.E.,

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Annemarie G.

Pace, Judge. Dismissed.

Cristina Gabrielidis, under appointment by the Court of Appeal, for Defendant

and Appellant.

Laura Feingold, County Counsel, Helena C. Rho, Deputy County Counsel for

Plaintiff and Respondent.

1 In this dependency case, M.E. (Mother), contends plaintiff and respondent San

Bernardino County Children and Family Services (CFS), failed to adequately inquire

into the possible Indian heritage of Mother’s children, Em.N.1 (a girl, born 12/2007),

D.H.N. (a boy, born 1/2009), Ev.N. (a girl, born 8/2010), D.D.N. (a boy, born 10/2011),

and J.N. (a boy, born 3/2015; collectively, the children). (Welf. & Inst. Code, § 224.2,

subd. (a).) CFS asserts that Mother’s appeal should be dismissed because Mother failed

to file a notice of appeal. We dismiss.

FACTS

Mother mailed a handwritten letter to the juvenile court. The envelope has two

postmarks on it. One postmark is dated July 8, 2025. The other postmark is dated

September 8, 2025. The juvenile court stamped the envelope as received on September

19, 2025. Mother’s letter has “Sunday” written in the top right corner, but no specific

date.

The letter reads, “To Whom It May Concern [¶] So I sit here writing another

letter because I do not have legal representation and seeing as w[h]ere I am I cannot file

any paper work [sic] or make copies to serv[e] anyone. I paid $5,000.00. And it was

for nothing. [T]he attorney never reach[es] out to me and don’t answer his calls and

didn’t show up or would be late to court. The attorney I hired before didn’t tell me he

was only a criminal law lawyer but he to[o] took [$]8,000 from me. So that has been a

problem.

1 Remittitur was issued November 25, 2025, on case No. J277536; Em.N. is not part of this appeal.

2 “Besides these proble[ms] once again I[’]m not surprised seeing as how our kids

were taken without cause. I have two things I need to ask the courts. One who is the

social worker the only one that actually investigated my case from day one? [¶] Two,

why is it Ms. Beverfall is not letting us rec[om]mend any family or friends to foster the

boys when it clearly states for us to find some one [sic] before a stranger does? [¶]

Please some one [sic] look into these questions they are a big part of my case. [¶] I feel

I am not getting a fair hearing and I will continue to appeal every thing [sic].”

The juvenile court filed Mother’s letter and on September 22, 2025, sent out a

clerk’s notification of the filing of a notice of appeal reflecting that the letter constituted

a notice of appeal.

DISCUSSION

CFS contends this court lacks jurisdiction over Mother’s appeal because

Mother’s letter is not a notice of appeal in that it does not indicate from what juvenile

court order Mother is appealing.

“ ‘[T]he timely filing of an appropriate notice of appeal or its legal equivalent is

an absolute prerequisite to the exercise of appellate jurisdiction.’ ” (K.J. v. Los Angeles

Unified School Dist. (2020) 8 Cal.5th 875, 881.) “[A] notice of appeal must be liberally

construed. [A] notice is sufficient if it identifies the particular judgment or order being

appealed.” (Cal Rules of Court, rule 8.100(a)(2).) “[I]f it is reasonably clear what [the]

appellant was trying to appeal from, and where the respondent could not possibly have

been misled or prejudiced,” then the notice of appeal is sufficient. (In re Joshua S.

(2007) 41 Cal.4th 261, 272.)

3 Mother’s letter does not specifically identify an order from which she is

appealing. Therefore, we will try to glean that information from context. In her letter,

Mother asserts that the children were removed without cause and she asks the juvenile

court for the name of the social worker who initially investigated the dependency

allegations. Mother’s concerns are focused on the juvenile court’s jurisdiction orders,

which were entered in September 2018, and/or the supplemental jurisdiction orders,

which were entered in May 2019. The deadline to appeal the jurisdiction and

supplemental jurisdiction orders has long passed. (Cal. Rules of Court, rule 8.406(a)(1)

[60 day deadline].) Accordingly, at this point, the jurisdiction orders and supplemental

jurisdiction orders cannot be the focus of a notice of appeal.

Also in Mother’s letter, she expresses that she would like her sons placed with

family or friends, rather than a foster family. When the children were initially removed,

Mother’s daughters were placed with their maternal grandmother while Mother’s sons

were placed with their maternal grandfather. In May 2019, all the children lived with

their maternal grandfather, Mr. E. By August 2019, all of the children were living in

foster homes. All but one of the children continued living in foster homes for the

remainder the case. The one child who left foster care resided in a group home and then

was released on wraparound services to the custody of his paternal uncle in March

2024. There were no major changes in the children’s placements in 2025, such that we

can determine a particular order that may have been the focus of Mother’s 2025 letter.

The envelope was postmarked on July 8, 2025, and September 8, 2025. Prior to

those dates, the children had a post-permanency review hearing on March 17, 2025.

4 July 8, 2025, and September 8, 2025, are more than 60 days past March 17, 2025, which

means the letter cannot be a notice of appeal for the March 17, 2025, orders. (Cal.

Rules of Court, rule 8.406(a)(1) [60 day deadline to appeal].)

In Mother’s appellant’s opening brief, she asserts that she is appealing from

orders made on September 17, 2025, at another post permanency review hearing.

Mother cannot be appealing from the September 17, 2025, orders because her letter was

postmarked on July 8, 2025, and September 8, 2025—before the September 17, 2025,

orders were made. There is a difference between liberally construing the content of a

notice of appeal and constructing a fictional notice. (See generally County of

Sacramento v. Pacific Gas & Elec. Co. (1987) 193 Cal.App.3d 300, 312 [we cannot

“construe ‘two percent’ to mean ‘four percent’ ”].) Reading the letter as a notice of

appeal from a hearing that occurred after the letter was sent would be a fiction.

In Mother’s appellant’s reply brief, she asserts CFS is not prejudiced by

construing Mother’s letter as a notice of appeal from the September 17, 2025, orders.

Mother asserts, “ICWA[2] inquiry obligations are ‘affirmative and continuing.’ (§

224.2, subd. (a).) ICWA-related errors remain reviewable in an appeal from a later

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