In re W.C. CA2/4

INTRODUCTION

V.N. (mother) previously appealed from a juvenile court order terminating her parental rights to her minor child, W.C. In that appeal, a different panel of this court conditionally affirmed the order terminating mother’s parental rights but remanded the matter with directions for the Los Angeles County Department of Children and Family Services (the Department) to comply with the inquiry requirements under the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.) and related California statutes (Welf. & Inst. Code, § 224 et seq.).1 On remand, the Department conducted an inquiry into claims of Native American heritage raised by W.C.’s parents. At the conclusion of the Department’s investigation, the juvenile court determined ICWA did not apply to this case and reinstated its previous order terminating mother’s parental rights to W.C. Mother now appeals from the order reinstating the termination of her parental rights to W.C., arguing the Department failed to satisfy its duty of inquiry under ICWA. We affirm, finding mother has forfeited her claim of error by failing to raise it in the juvenile court below, and that the juvenile court’s findings were supported by…