In re Bella L.

FACTS AND PROCEDURAL BACKGROUND2

I. The Family

Suemi P. (mother) and Diego L. (father) have two children relevant to this appeal—namely, Bella L. (born June 2018) and Emma L. (born April 2022) (collectively, “the children”).

II. Section 300 Petition and Initial ICWA Inquiry

On July 25, 2022, the Los Angeles County Department of Children and Family Services (the Department) filed a petition asking the juvenile court to exert dependency jurisdiction over the children under section 300, subdivision (b)(1) due to father’s domestic violence against mother and mother’s failure to protect the children from that violence.4 The day after the petition was filed, mother and father each filed ICWA-020 forms in which they denied knowledge of any Native American heritage, and the juvenile court held an initial hearing on the petition and removed the children from the parents’ custody. At that hearing, the court acknowledged the parents’ responses on their ICWA-020 forms; informed the parents “to notify their attorney, the social worker, and the court”

Because the only challenge on appeal is to the sufficiency of the ICWA inquiry, we limit our discussion to the facts relevant…