Los Angeles County v. Bridget C.

In this dependency case, it is conceded that the notice requirements under the Indian Child Welfare Act ( 25 U.S.C. § 1901 et seq.) (ICWA) were not met. We hold that this deficiency does not impact the jurisdictional and dispositional orders previously made in this proceeding.

BACKGROUND

Bridget C., mother of Brooke C. (bom in 1998), appeals from an order denying family reunification services based upon a finding that Bridget had *380 resisted treatment pursuant to section 361.5, subdivision (b)(13) of the Welfare and Institutions Code. 1 Bridget contends that the court erred (1) in failing to grant her reunification services, because the evidence does not show that Bridget resisted treatment and the court failed to properly consider the detriment to Brooke, and (2) in failing to ensure that the notice requirements under the ICWA were met.

In December 2003, Brooke’s father, Robert G., notified police that while visiting Brooke, he saw Bridget showing symptoms of drug use. He found a Vicodin pill near Bridget’s bed and within Brooke’s reach. Officers arrived and found Bridget disoriented, lethargic, confused, and unable to speak clearly or walk straight. A social worker…