In re A.J. CA3

FACTS

Appellant was arrested for domestic violence in December 2008. The Agency filed a petition to detain one-year-old A.J. in January 2009 due to parental substance abuse, anger and mental health problems. The juvenile court ordered reunification services for both parents. Eva J. was born in November 2009 and removed from parental custody. Reunification services continued to be provided; however, the parents made little progress, testing positive for drugs and alcohol, failing to attend programs and continuing to engage in domestic violence. In April 2010, the juvenile court terminated services as to A.J., denied services for Eva. J., and set a section 366.26 hearing for both minors. While the hearing was pending and appellant was in custody, appellant gave birth to E.J. who was detained and placed with his siblings. The juvenile court denied services for E.J. in February 2011 and set a section 366.26 hearing. The same day, parental rights were terminated as to A.J. and Eva J. Parental rights were terminated as to E.J. in June 2011. The parents appealed the termination orders in case Nos. C067484 and C068578. The appeals challenged the inquiry and adequacy of notice under ICWA.…