In re M.S. CA2/8

INTRODUCTION

Michelle R. (Mother) appeals from the orders terminating parental rights over her two minor children under Welfare and Institutions Code1 section 366.26. On appeal, Mother argues the juvenile court erred in failing to apply the beneficial parental relationship exception to the termination of her parental rights. (§ 366.26, subd. (c)(1)(B)(i).) She also asserts the juvenile court and the Los Angeles County Department of Children and Family Services (DCFS) failed to comply with the inquiry requirements of the Indian Child Welfare Act of 1978 (ICWA; 25 U.S.C. § 1901 et seq.) and related California law. We conclude that neither of Mother’s arguments has merit, and accordingly, affirm.

FACTUAL AND PROCEDURAL BACKGROUND

1. Section 300 petition Mother and Michael S. (Father) are the parents of M.S., a boy born in March 2020, and J.S., a girl born in February 2021. Father is not a party to this appeal. On April 6, 2023, DCFS filed a dependency petition for M.S. and J.S. under section 300, subdivisions (a) and (b), alleging that the children were at substantial risk of harm based on Father’s history of domestic violence against Mother, and Mother’s failure to protect…