In re B.O. CA4/2

BACKGROUND

The relevant background is brief. CFS obtained a protective custody warrant

(§ 340) under which it detained Minor soon after he tested positive for fentanyl and

amphetamine at birth. CFS filed a dependency petition on grounds Father and S.O.

(Mother) failed to protect Minor from serious physical harm and Father failed to reunify

with a half-sibling. (§ 300, subds. (b)(1), (j).)

1 All further statutory references are to the Welfare and Institutions Code unless otherwise indicated. We note that, like the Supreme Court, we use the term “Indian” to reflect the statutory language. No disrespect is intended. (In re Dezi C. (2024) 16 Cal.5th 1112, 1125, fn. 1.)

2 During the course of CFS’s investigation, social workers spoke to Minor’s

maternal grandmother (MGM) on more than one occasion, but nothing in the record

indicates she was asked whether Minor might have Indian ancestry. MGM advised the

workers of other relatives to be considered for placement, including, in a separate

household, maternal grandfather “Michael.” MGM provided his and another relative’s

contact information. The record does not suggest CFS inquired of any maternal relatives

regarding the…