Los Angeles County Department of Children & Family Services v. Roland C.

INTRODUCTION

Roland C. (father) appeals a jurisdictional finding and dispositional order in the dependency case of his three children, Natalie A., Jocelyn and Jeremiah. All three children were under age six when the events underlying this appeal occurred. Father contends the evidence was insufficient to find he is a current abuser of marijuana. He also argues the juvenile court abused its discretion by ordering him to complete substance abuse related services as part of his dispositional case plan. We conclude father’s admitted use of marijuana, his failure to ensure his very young children were adequately supervised, and his absent drug tests all constituted sufficient evidence to support both the jurisdictional finding and the dispositional order.

Father also contends he provided sufficient information of possible Indian heritage to trigger the Indian Child Welfare Act of 1978’s (ICWA; 25 U.S.C. § 1901 et seq.) notice provisions. We agree. Accordingly, we reverse the court’s finding in that regard, and remand with directions to comply with ICWA’s notice requirements. In all other respects we affirm.

*181 FACTS AND PROCEDURAL BACKGROUND

At the time of the following…