In re R.M. CA2/5

INTRODUCTION

Mother appeals from the juvenile court’s termination of her parental rights to her son, R.M. She argues the court and the Department of Children and Family Services (DCFS) failed to satisfy their duty of further inquiry into R.M.’s maternal lineage under the Indian Child Welfare Act (ICWA). We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

1. Prior Dependency History R.M. is mother’s fifth child. Mother lost custody of her first four children due to drug abuse. Most recently, mother’s fourth child, M.G. was the subject of dependency proceedings in San Bernardino County juvenile court (case No. 0000272967.)1 In that case, mother claimed Blackfeet, Choctaw, Cherokee, Chickasaw, and Chippewa ancestry. On March 12, 2019, after DCFS noticed those tribes, the San Bernardino court made a finding that ICWA did not apply. The actual ICWA notices filed in San Bernardino were not made part of the record in the present dependency proceedings. On July 28, 2019, the San Bernardino court terminated mother’s parental rights to M.G., and he was freed for adoption. 2. Juvenile Court Proceedings as to R.M. In May 2019, a few days after his birth, DCFS detained R.M. On May 9, 2019,…