In re A.R.R. CA2/4

INTRODUCTION

Dora L. (mother) and Eduardo A. (father) appeal the orders terminating their parental rights under Welfare and Institutions Code section 366.26.1 Mother argues the trial court erred in failing to apply the parental-benefit exception under section 366.26, subdivision (c)(1)(B)(i). Father contends the Los Angeles County Department of Children and Family Services (the Department) failed to comply with the inquiry requirements under the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.) and related California statutes (§ 224 et seq.). We find the juvenile court did not err in declining to apply the parental-benefit exception. However, we conditionally reverse the juvenile court’s orders terminating parental rights and remand to the juvenile court with instructions to comply with ICWA’s inquiry requirements. Mother also appeals the juvenile court’s orders denying her petitions for modification under section 388. We affirm. As the parties are familiar with the facts and procedural history of the case, we do not restate those details in full here. Below, we discuss only the facts and history as needed to resolve—and provide context for—the issues presented on…