In re Joseph P. CA4/2

BACKGROUND

A.R. (Father) appeals from the termination of his parental rights to his minor son,

Andres R. D.P. (Mother) appeals from the termination of her parental rights to her minor

sons, Andres and Joseph P. (collectively, the children). The parents argue that the

juvenile court erred by failing to apply the beneficial parental relationship exception

under subdivision (c)(1)(B)(i) of Welfare and Institutions Code section 366.26 (unlabeled

statutory references are to this code). Father also argues that the Riverside County

Department of Public Social Services (DPSS) and the juvenile court failed to comply

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

state law. We disagree and affirm.

I. Detention

“[Mother and] Father’s one-year-old son, Andres R., [and Mother’s nearly four-

year-old son, Joseph P.,] came to DPSS’s attention in May 2022, when [Mother] called

law enforcement to report domestic violence. Mother reported that Father put her in a

headlock and choked her. She freed herself from the headlock and tried to call law

enforcement, but Father grabbed her phone and threw it. He then drove off. Mother put

Andres…