In re T.N. CA4/2

CourtCalifornia Court of Appeal
DecidedSeptember 17, 2024
DocketE082446
StatusUnpublished

This text of In re T.N. CA4/2 (In re T.N. 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 T.N. CA4/2, (Cal. Ct. App. 2024).

Opinion

Filed 9/17/24 In re T.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NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 T.N., a Person Coming Under the Juvenile Court Law.

RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, E082446

Plaintiff and Respondent, (Super.Ct.No. DPRI2200126)

v. OPINION

K.A.,

Defendant and Appellant.

APPEAL from the Superior Court of Riverside County. Dorothy McLaughlin,

Judge. Affirmed.

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

Appellant.

Minh C. Tran, County Counsel, and Teresa K.B. Beecham and Julie Jarvi, Deputy

County Counsel, for Plaintiff and Respondent.

1 K.A. (mother) appeals from orders terminating her reunification services. She

argues the Riverside County Department of Public Social Services (department) failed to

provide reasonable reunification services. Relatedly, she argues the department violated

the Indian Child Welfare Act (ICWA) by failing to make active efforts to prevent the

breakup of an Indian family. The department argues it provided reasonable reunification

services. It also argues the ICWA active efforts duty does not apply here because,

although the child is apparently eligible for membership in a tribe, he is not yet enrolled

and therefore is not yet an Indian child. We conclude there is substantial evidence the

department provided reasonable reunification services. The juvenile court has not yet

made any ruling on whether the department made active efforts to prevent the breakup of

an Indian family, so that issue is not ripe.

BACKGROUND

This dependency concerns mother’s minor child T.N. (born 2021).

In October 2022 the department received a referral alleging the parents neglected

T.N. and engaged in domestic violence. Specifically, the referral alleged that mother

attacked father with a butter knife, that she seemed paranoid, that she was distressed and

panicked whenever T.N. cried, and that she generally suffered from mental health issues.

The parents also allegedly “had a history of domestic violence with law enforcement

involvement.”

The department visited the parents’ home and spoke to father. Father told the

department mother had a diagnosis of schizophrenia, depression, and anxiety. He said

2 she was supposed to take medication, but had not done so for almost two months. He

also said there were a dozen similar domestic violence incidents in the past. However,

father said mother was never violent towards T.N. He said that he considered leaving

mother and taking T.N. but felt he could not do so because mother was not capable of

caring for herself.

Mother confirmed she was no longer taking her medication. The department also

reported that she had a history of abusing controlled substances such as alcohol and

marijuana, and was volatile while under the influence of alcohol. Mother was also

involuntarily committed under Welfare and Institutions Code section 51501 shortly after

T.N.’s birth.

The department removed T.N. via a protective custody warrant, and filed a

petition under section 300, subdivision (b)(1). The petition alleged the parents had a

history of domestic violence, mother suffers from unresolved mental health issues,

mother had a history of substance abuse and volatile behavior while under the influence,

and father had a history of marijuana abuse.

Shortly thereafter, mother informed the court and the department that T.N. may be

a member of, or eligible for membership in, the Oklahoma Cherokee tribe.

At the detention hearing, the court found the petition stated a prima facie case for

all allegations except the substance abuse allegation against father, and detained T.N.

The court asked both parents about their Indian ancestry, and both mother and mother’s

1 Undesignated statutory references are to the Welfare and Institutions Code.

3 counsel informed the court that maternal great-grandmother is a registered member of the

Cherokee tribe. Accordingly, the court found there was reason to believe T.N. is an

Indian child. The department subsequently followed up with the maternal grandmother,

who confirmed she was a registered member of a tribe.

The department interviewed the parents again before the jurisdiction and

disposition hearing. Mother admitted to domestic violence incidents, including one

incident in 2015 where she stabbed father “partly on the neck, leg, and hand with a large

knife,” which resulted in her arrest. She also admitted to trying to stab father with a

butter knife in the most recent domestic violence incident. Mother said she completed

high school and some community college. She was unemployed and waiting to be

approved for disability. Mother told the department “she did not feel capable of caring

for the child, and wanted the father to reunite and keep the child, until she figures out her

life.” However, she did not agree to relinquish T.N. She also told the department she

suffered from post-traumatic stress disorder and depression.

Father elaborated on mother’s struggles with her mental health and other cognitive

issues. He said he removed the TV from their home because she thought people were

watching her through it, and that she stopped eating food he cooked because she thought

he poisoned it. He also alleged that she has a learning disability and “[s]he can’t count,

she can’t read, [and] she can’t keep track of time.” According to father, mother did not

graduate high school until she was 21. He said her mental health got worse after T.N.’s

4 birth, and that he can no longer take care of both her and T.N. He also expressed

frustration that she would not engage in parenting classes.

The department referred mother to domestic violence for perpetrators classes,

substance abuse services, individual therapy, and parenting education. It also provided a

referral for a parent partner.

The court held an initial jurisdiction hearing in November 2022. However, it

found exceptional circumstances to continue it to allow for further ICWA inquiry and

noticing. Accordingly, the court ordered the department to send ICWA notices to the

Bureau of Indian Affairs (BIA). It also authorized a psychological evaluation for mother.

In December 2022 the Cherokee Nation responded to the department’s notice. It

informed the department that T.N. “can be traced in our tribal records based on the

extended family member/s highlighted above.” It advised that T.N. was not currently an

Indian child, and that the tribe therefore did not have jurisdiction to intervene. However,

it included information for how to enroll T.N. in the tribe. The department provided the

enrollment information to mother. Mother informed the department she already had an

enrollment packet, but the packet she showed the department was unrelated to tribal

enrollment. The department then “offered assistance for the child’s enrollment.” To

assist, the department contacted the Eligibility Supervisor for the Cherokee Nation, who

confirmed T.N.

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Bluebook (online)
In re T.N. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-tn-ca42-calctapp-2024.