In Re Melissa R.

Linda J. Conrad, under appointment by the Court of Appeal, for Minor.

Melissa R. is a 20-year-old woman with severe developmental disabilities. She needs assistance in all of her activities of daily living, and will need it for the rest of her life. This appeal concerns the juvenile court's decision to terminate dependency jurisdiction and leave Melissa's placement in her group home. S.V. (Mother) contends the court erred when it dismissed dependency jurisdiction; that the evidence does not show a risk of detriment to Melissa if she were returned to Mother's care; and that lack of compliance with the Indian Child Welfare Act of 1978 ( 25 U.S.C. § 1901 et seq.) (ICWA, or the Act) requires reversal. We conclude the court properly dismissed dependency jurisdiction and allowed Melissa to remain in her group home, and that Mother's challenge to the risk of detriment finding is moot. We also conclude that reversal and remand to require the juvenile court to comply with ICWA would be futile because Melissa has reached the age of majority and, therefore, is not an "Indian child" within the meaning of the Act. We therefore affirm the juvenile court orders.

Melissa was born…