In re Ta.B. CA2/4

INTRODUCTION

In a juvenile court case that has been pending for more than a decade, the trial court found the minor, Ta., adoptable and terminated the parental rights of Tiffany P. (mother) under Welfare and Institutions Code section 366.26.1 Mother appealed. She asserts that the juvenile court erred in finding Ta. adoptable because he has special needs. We find no error in this finding. Mother also asks us to consider evidence that after the section 366.26 hearing, Ta.’s planned adoption fell through. We follow controlling Supreme Court authority and hold that we may not rely upon evidence of events occurring after the termination of mother’s parental rights to reverse the juvenile court’s ruling. Finally, mother asserts that the inquiry under the Indian Child Welfare Act (ICWA) was insufficient. We find no error and affirm the juvenile court’s ruling.

FACTUAL AND PROCEDURAL BACKGROUND

The extensive facts of this case are summarized in several previous decisions: In re T.P. (Feb. 6, 2020, B297465) [nonpub. opn.], In re T.P. (Mar. 30, 2023, B313540) [nonpub opn.], and In re T.P. (Dec. 1, 2023, No. B322047) [nonpub. opn.]. In the sections below, we summarize the evidence…