San Diego Cnty. Health & Human Servs. Agency v. Sally H. (In re E.H.)

*1062 I

INTRODUCTION

Sally H. (Mother) appeals a judgment terminating her parental rights to her child, E.H. Mother's sole claim on appeal is that that the juvenile court erred in terminating her parental rights because the court failed to ensure that the San Diego County Health and Human Services Agency (Agency) fully complied with the inquiry and notice requirements of the Indian Child Welfare Act of 1978 (ICWA; 25 U.S.C. § 1901 et. seq. ) and related law.

Among other alleged errors, Mother contends that the Agency failed to fulfill its duty to inquire of E.H.'s maternal great-grandmother, Sally Y.H., in order to obtain identifying information pertaining to Sally Y.H.'s father, and failed to provide notice of such information to an Indian tribe named the Tohono O'odham Nation. Mother further contends that the failure to provide notice of Sally Y.H.'s father's identifying information to the Tohono O'odham Nation was prejudicial because he was likely the source of E.H.'s possible American Indian heritage. In support of this contention, Mother notes that the record indicates that Sally Y.H. told the Agency that her paternal family had heritage from the Tohono O'odham Nation.…