In re G.H. CA4/2

INTRODUCTION

L.C. (father) appeals from the juvenile court’s order terminating parental rights as

to his child, G.H. (the child). Father’s sole contention on appeal is that the juvenile court

and the Riverside County Department of Public Social Services (DPSS) failed to comply

with the duty of inquiry under the Indian Child Welfare Act of 1978 (25 U.S.C. § 1901 et

seq.) (ICWA) and related California statutes, particularly Welfare and Institutions Code1

section 224.2, subdivision (b). Specifically, he argues that DPSS failed to comply with

the duty of initial inquiry by not inquiring of all available extended relatives about the

child’s potential Indian ancestry. We filed an opinion affirming on the ground that the

duty did not apply since the child was taken into custody pursuant to a protective custody

warrant under section 340.

The Supreme Court granted review and subsequently transferred the case back to

this court with directions to vacate our prior opinion and reconsider the cause in light

of In re Ja.O. (2025) 18 Cal.5th 271 (Ja.O.). We vacated our opinion and directed the

parties to file supplemental briefs, limited to matters arising after this court’s…