Los Angeles County Department of Children & Family Services v. Rachel D.

Mother Rachel D. (Mother) appeals an order terminating her parental rights to her son J.D. pursuant to Welfare and Institutions Code section 366.26. 1 She contends notice was inadequate under the Indian Child Welfare Act of 1978 (ICWA) ( 25 U.S.C. § 1901 et seq.). We affirm.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

On May 1, 2008, the Los Angeles County Department of Children and Family Services (Department) responded to a referral from Kester Elementary School that eight-year-old J.D. and his older sister Ja.D. were the victims of general neglect. J.D. told the social worker that Mother had hit him with a belt in the past, and that Mother used physical discipline consisting of her open palm and her fists. The day before, Mother had struck J.D. on the back. The social worker observed bruises and contusions on J.D.’s arm and back, and a scratch on his arm from Mother’s fingernail. The school’s principal reported that Mother had recently enrolled the children without documentation and cursed at school personnel, informing them that a very wealthy person searched for her and paid people to follow her. When interviewed at the police department, Mother denied abusing the…