In re L.S. CA2/5

background relevant to that issue. Mother’s involvement with the juvenile dependency system dates back to 1997, when the Department filed a petition alleging mother (born in 1992) and her siblings were at risk of abuse and neglect. Mother has a sixteen-year history of alcohol and drug abuse, and parental rights to her two oldest children (born 2007 and 2009) were terminated in 2012. Also in 2012,

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

2 two of mother’s children, O.S. (born 2011) and Le.S. (born 2012), were declared dependents based on mother’s substance abuse. Those children subsequently returned to mother’s custody, and the court terminated jurisdiction in August 2013; however, by 2019 they were residing in Mexico with their paternal grandmother. The appellate record contains no information about any ICWA findings or inquiry efforts related to these prior dependency cases. Minor was born in September 2019, and was detained from mother after testing positive for amphetamine and methamphetamine at birth. The detention report states minor is not an Indian child and includes a judicial council form (ICWA-10) stating the…