In re J.F. CA4/3

INTRODUCTION

G.G. (Mother) is the mother of J.F., Ja.F., M.F., and G.F (collectively the Minors), who were taken into protective custody in July 2025. V.G. (Father) is the presumed father of M.F. and G.F. Mother and Father appeal from dispositional orders declaring the Minors to be dependent children of the court and removing them from parental custody. Mother and Father’s sole claim of error is the juvenile court’s finding that the Indian Child Welfare Act, 25 U.S.C. section 1901 et seq. (ICWA) did not apply. Mother and Father argue that Orange Counsel Social Services Agency (SSA) did not undertake the required ICWA inquiry before the juvenile court made the dispositional orders. SSA concedes it did not fulfill its duty of inquiry under ICWA. SSA disagrees with Mother and Father, however, over what our disposition should be. SSA contends we should vacate the ICWA findings and otherwise affirm the dispositional orders with directions. Mother and Father contend we should conditionally reverse the dispositional orders with directions for the juvenile court and SSA to comply with its duty of inquiry under ICWA. We conclude the proper disposition is to vacate the ICWA findings and…