In re A.B. CA4/2

I. INTRODUCTION

On August 21, 2025, the juvenile court held a hearing pursuant to Welfare and

Institutions Code1 section 366.26 and terminated the parental rights of A.B. (Mother)

with respect to her two children, Am.B. and A.S. Mother appeals from the orders

terminating her parental rights, arguing only that San Bernardino County Children and

Family Services (CFS) failed to comply with its duty of inquiry under the Indian Child

Welfare Act of 1978 (ICWA; 25 U.S.C. § 1901 et seq.) and related California statutes.

Specifically, Mother argues that: (1) CFS failed to conduct an adequate inquiry of

maternal relatives; and (2) CFS failed to conduct an adequate inquiry related to the

paternal relatives of A.S.

We conclude that the record is sufficient to support a finding that CFS conducted a

reasonable ICWA inquiry with respect to Am.B. However, CFS concedes, and we agree,

that the record is inadequate to support a finding that CFS complied with its duty of

inquiry with respect to the paternal relatives of A.S. As such, we conditionally reverse

the order terminating Mother’s parental rights to A.S.

II. FACTS AND PROCEDURAL HISTORY3

Mother has two biological children…