In re P.S. CA4/2

INTRODUCTION

S.S. (mother) appeals from the juvenile court’s order terminating parental rights

(Welf. & Inst. Code,1 § 366.26) as to her child, P.S. (the child). Mother contends the

matter must be conditionally reversed and remanded because the San Bernardino County

Children and Family Services (CFS) failed to discharge its duty of inquiry under the

Indian Child Welfare Act of 1978 (25 U.S.C. § 1901 et. seq.) (ICWA) and related

California law (§ 224.2). J.H. (father) has filed a separate brief simply joining in

mother’s arguments. We affirm.

PROCEDURAL BACKGROUND

On April 3, 2022, mother gave birth to the child at a county hospital in Parker,

Arizona. Mother tested positive for amphetamines. The child showed symptoms of

withdrawal, had high-pitch screams and loose stools, and “needed morphine as part of her

treatment.” Mother admitted to taking methadone, and she admitted to taking fentanyl

throughout her pregnancy. She completed a hair follicle test on April 15, which came

back positive for methamphetamine. Mother stated she had been living in Earp,

California for almost a year and a half, but she continued to collect benefits and medical

insurance in Arizona…