In re J.S. CA2/4

background that gave rise to the termination of parental rights, so we do not restate those details. We simply provide context for our resolution of the narrow ICWA issue presented. (People v. Garcia (2002) 97 Cal.App.4th 847, 851.)

2 [nonpub. opn.] (J.S.).)3 A different panel of this court affirmed the order terminating mother’s parental rights, concluding that any purported ICWA deficiencies were harmless, in part because both parents clearly denied Indian ancestry. (J.S., supra,

B330027.)

Six weeks after this court filed its opinion deciding mother’s first appeal, our Supreme Court issued In re Dezi C. (2024) 16 Cal.5th 1112 (Dezi C). Dezi C. states: “When there is an inadequate inquiry and the record is underdeveloped, it is impossible for reviewing courts to assess prejudice because we simply do not know what additional information will be revealed from an adequate inquiry. We therefore hold that an inadequate Cal-ICWA inquiry requires conditional reversal of the juvenile court’s order terminating parental rights with directions to the agency to conduct an adequate inquiry, supported by record documentation.” (Dezi C., at p. 1125.) Dezi C. “reverse[d] the judgment of the…