In re A.D. CA2/8

INTRODUCTION

M.R. (Mother) and Robert B. (Father) appeal from the juvenile court’s dispositional order, declaring their children dependents of the court under Welfare and Institutions Code1 section 300, subdivisions (a) and (b), and removing them from parental custody. Mother argues the court abused its discretion in ordering her to participate in a domestic violence support group for victims. Both parents assert the court and the Los Angeles County Department of Children and Family Services (Department) failed to comply with the applicable provisions of the Indian Child Welfare Act of 1978 (ICWA; 25 U.S.C. § 1901 et seq.) and related California law. We conclude the juvenile court did not abuse its discretion in requiring Mother to participate in a domestic violence support group as part of her reunification services. However, the Department concedes, and we agree, that the ICWA inquiry was inadequate. Accordingly, we conditionally affirm the dispositional order and remand for ICWA compliance.

FACTUAL AND PROCEDURAL BACKGROUND

Mother has two children that are the subject of the current proceedings: A.D., a girl born in November 2012, and R.B., a boy born in December 2017.…