In re E.G. CA2/5

background relevant to that issue. Minor, who was born in 2013, was the subject of an earlier dependency case based on substance abuse by both parents.2 The initial section 300 petition in that case was filed in 2014,

1 Further statutory references are to the Welfare and Institutions Code unless stated otherwise.

2 Minor’s father, C.C., is not a party to this appeal.

2 and the court found that ICWA did not apply. The case ended in 2017 with an award of physical and legal custody to mother. The current dependency case began in the summer of 2018, based on a deterioration in mother’s mental health and her refusal to contact investigating social workers. During their initial investigation, social workers spoke to maternal grandmother and a 17-year-old maternal uncle, both of whom had been living with mother until she had a psychiatric hospitalization. Maternal grandmother would not give the social worker mother’s telephone number, but said she would ask mother to call the social worker. The Department detained minor (then four years old), placing her with maternal grandmother and instructing maternal grandmother that mother could not see minor until after a detention hearing…