Ventura Cnty. Human Servs. Agency v. A.N. (In re R.H.)

A.N. (mother) appeals the juvenile court's order terminating her parental rights to R.H., an Indian child, and selecting adoption as his permanent plan. ( Welf. & Inst. Code, 1 § 366.26.) Mother contends the court erred in finding good cause to depart from the placement preferences set forth in the Indian Child Welfare Act (ICWA). 2 She also asks us to take as additional evidence a letter her appellate counsel received from R.H.'s tribe over three months after the judgment was rendered indicating that the tribe-which repeatedly declined the opportunity to intervene below-wants to "be involved in the case." Although an Indian tribe may intervene in state court dependency proceedings at any time ( 25 U.S.C. § 1911 (c) ), R.H.'s tribe has yet to intervene here. Accordingly, we deny mother's request and affirm.

FACTS AND PROCEDURAL HISTORY

R.H. was born in December 2015. In April 2016, mother was arrested on an outstanding warrant. The Ventura County Human Services Agency (HSA) filed a dependency petition as to R.H. alleging failure to protect, no provision for support, and abuse of a sibling (§ 300, subds. (b), (g), & (j)). The petition alleged that mother and R.H.'s father…