In re W.L. CA4/2

FACTS

Appellants are the mother and father of W.L. (born Feb. 2021). Both parents have

long struggled with substance abuse, and particularly abuse of methamphetamines.

Plaintiff and respondent San Bernardino County Department of Children and Family

Services (department) filed a dependency petition in May 2021, alleging the child came

within section 300, subdivision (b)(1) (failure to protect), because of the parents’

substance abuse issues, the failure by each to protect the child from substance abuse by

the other, as well as mother’s “long criminal history,” much of which relates to substance

1 Undesignated statutory references are to the Welfare and Institutions Code. “In addition, because 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.” (In re Benjamin M. (2021) 70 Cal.App.5th 735, 739, fn. 1. (Benjamin M.).)

2 abuse. Father, too, had a substantial criminal history, but the department did not include

any allegation about it in the petition.

In a previous dependency, mother failed to reunify with the child’s older half-

sibling, her parental…