In re I.B.

Under the federal Indian Child Welfare Act of 1978 (ICWA) ( 25 U.S.C. § 1901 et seq.) and the related California statutes governing custody proceedings involving Indian children (Welf. & Inst. Code, § 224 et seq.), when a juvenile court in dependency proceedings knows or has reason to know that an Indian child is involved, the party seeking the foster care placement of, or termination of parental rights to, that child must notify the child’s tribe of the pending proceedings and of the tribe’s right of intervention. ( 25 U.S.C. § 1912 (a); Welf. & Inst. Code, § 224.2, subd. (a).) That notice must include, among other things, the names (including maiden, married, and former names or aliases), birth dates, places of birth and death, tribal enrollment numbers, and any other identifying information, to the extent it is known, of the Indian child’s biological parents, grandparents, and great-grandparents. ( 25 C.F.R. § 23.11 (a), (d)(3) (2015); Welf. & Inst. Code, § 224.2, subd. (a)(5).)

The issue presented in this case is whether there is a duty under the ICWA to send updated notices to the relevant tribes when additional information regarding the child’s ancestors (such as…