In re Z.O. CA2/4

INTRODUCTION

E.O. (Mother) appeals from an order of the juvenile court terminating her parental rights to her daughter, Z.O. Mother’s sole contention on appeal is that the Los Angeles County Department of Children and Family Services (DCFS) failed to comply with the inquiry and notice requirements of the federal Indian Child Welfare Act of 1978 (ICWA) (25 U.S.C. § 1901 et seq.) and the analogous California statutes governing custody proceedings involving Indian children (Welf. & Inst. Code, § 224 et seq.).1 We conclude, based upon the certified documents provided to us by DCFS with its motion to augment the record on appeal, which motion we grant, that the inquiry and notice conducted was in full compliance with the requisites of the statute and therefore affirm the order terminating parental rights.

FACTUAL AND PROCEDURAL BACKGROUND

Z.O. (born in Apr. 2010) was removed from Mother’s custody in February 2011 based on a referral alleging Mother had physically attacked the maternal grandmother in the child’s presence. A relative advised DCFS that the family had native American Indian ancestry. DCFS sent notices to the appropriate tribes as required by the ICWA. At the…