In re Q.G. CA4/2

I.

INTRODUCTION

K.S. (Mother) appeals the juvenile court’s jurisdictional/dispositional orders as to

her one-year-old child Q.-Z.G. (Q.) Mother argues that the court and the Riverside

County Department of Public Social Services (DPSS) failed to comply with the Indian 1 Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.) and related state law. We

conclude that further ICWA inquiry is required. We therefore conditionally remand the

matter for further proceedings to ensure ICWA compliance.

II.

FACTUAL AND PROCEDURAL BACKGROUND2

A. General Background

The family came to the attention of DPSS in January 2021 after Q. was born

premature at 33 weeks and Mother tested positive for THC following Q.’s birth. Q. was

very small, had trouble feeding and breathing on her own, and was deemed to be

medically fragile by a nurse. Despite Q.’s medical issues, Mother demanded to take the

child from the hospital. Mother also engaged in domestic violence with Father while

visiting Q. at the hospital and was arrested for assault with a deadly weapon and corporal

1 D.G. (Father) is not a party to this appeal. 2 As the sole issue on appeal concerns ICWA compliance, we only briefly discuss…