In Re CB

"One of the key elements of any interstate compact is uniformity in interpretation. Uniformity, however, is lacking with respect to the issue of whether the [Interstate Compact on the Placement of Children] applies to the placement of a child with a natural parent ...." (Butler, Child Welfare—Outside the Interstate Compact on the Placement of Children— Placement of a Child With a Natural Parent (1992) 37 Villanova L.Rev. 896, 916, fn. omitted.)

As we will discuss, California cases have consistently held that the Interstate Compact on Placement of Children (ICPC; Fam. Code, § 7900 et seq.) does not apply to an out-of-state placement with a parent. They have even gone so far as to invalidate statewide rules and regulations that purported to make the ICPC apply. Other jurisdictions that have taken the same position include Arkansas ( Arkansas Dept. of Human Services v. Huff (2002) 347 Ark. 553, 562-564 [ 65 S.W.3d 880, 886-888 ]), New Hampshire ( In re Alexis O. (2008) 157 N.H. 781, 788-791 [ 959 A.2d 176, 182-185 ]), New Jersey ( State, DYFS v. K.F. (2002) 353 N.J.Super. 623 , 631-636 [ 803 A.2d 721 , 726-729]), Washington ( In re Dependency of D.F.-M. (2010) 157…