In re B.C. CA2/4

INTRODUCTION

E.P. (father) appeals from the juvenile court’s order terminating his parental rights with respect to his son, B.C.1 Father raises a single issue: whether the Los Angeles Department of Children and Family Services (Department) properly inquired into B.C.’s Indian ancestry, as required by the Indian Child Welfare Act (25 U.S.C. § 1901 et seq.) (ICWA) and related state law. We hold that the Department’s inquiry was incomplete. However, we conclude that the Department’s omission was harmless. Therefore, we affirm the orders of the juvenile court.

FACTUAL AND PROCEDURAL BACKGROUND

B.C. was born in January 2022. The Department filed a dependency petition on behalf of B.C. under Welfare and Institutions Code section 300, subdivision (b)(1).2 The petition alleged that B.C. tested positive for amphetamines at birth, as did his mother, M.C. (mother), immediately prior to birth. The petition also alleged that father knew or should have known about mother’s substance use and failed to protect B.C. In the ICWA attachment to the petition, the Department indicated that it had questioned mother about the child’s Indian status. Mother denied that B.C. had Indian ancestry. The…