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

Jennifer C. (Mother) appeals from the termination of her parental rights over her daughter, Charlotte V., on the ground the juvenile court failed to comply with the strict notice requirements specified in the Indian Child Welfare Act of 1978 (ICWA) ( 25 U.S.C. § 1901 et seq.; see also Welf. & Inst. Code, § 224 et seq.) We affirm.

FACTS

Charlotte, born in 2011, is the daughter of Mother and Mario V. (Father). A juvenile dependency petition was filed on July 3, 2013, alleging Mother and *54 Father endangered Charlotte’s physical health and safety, as provided under Welfare and Institutions Code, section 300, subdivision (b). The petition alleged Mother repeatedly rammed her car into Father’s while Charlotte was sitting in the backseat of Mother’s car on June 27, 2013. Mother also brandished a loaded handgun at Father. The handgun was within Charlotte’s reach inside the car. Mother and Father wrestled for the handgun. Father was arrested for concealing a firearm and Mother was arrested for child endangerment.

The juvenile court ordered Charlotte detained and placed with her maternal uncle. Charlotte was ultimately placed with a foster family after the dependency…