In re G.C.

In this case, we address the issue of whether a party, by not objecting in the trial court, forfeits an objection to the failure to follow procedures related to an alternative permanent plan for Indian children established by the Legislature—tribal customary adoption—which became operative on July 1, 2010. (Stats. 2009, ch. 287, § 12.)

Father, G.C. (father), appeals a December 2011 order terminating his parental rights to the minor. He contends the juvenile court did not comply with Welfare and Institutions Code section 366.24 and ensure the minor’s Indian tribe considered the appropriateness of a tribal customary adoption. The Children’s Services Division of the Butte County Department of Employment and Social Services (the Department) initially conceded the claim, stating that because the social workers and the Indian child welfare expert did not address the issue of tribal customary adoption, the matter must be reversed and remanded to allow for proper consideration. We requested supplemental briefing. The Department now contends the issue is forfeited and any error was harmless. We agree.

We hold that to preserve claims related to the failure to follow the tribal…