In re P.M. CA4/2

I.

INTRODUCTION

P.R. (Mother) appeals from the juvenile court’s order terminating parental rights 1 as to her four-year-old daughter P.M. (Welf. & Inst. Code, § 366.26). Mother contends

that the juvenile court and the San Bernardino County Children and Family Services

(CFS) failed to comply with the duty of inquiry under the Indian Child Welfare Act of 2 1978 (ICWA) (25 U.S.C. § 1901 et seq.) and related state law, and therefore substantial 3 evidence did not support the court’s finding ICWA did not apply. For the reasons

explained, we affirm the order terminating parental rights.

II.

FACTUAL AND PROCEDURAL BACKGROUND

A. General Background

This case involves Mother’s sixth child. Mother has a prior history with child

protective services involving five of her other children due to issues with substance abuse

and domestic violence in the home. Prior to this case, three of Mother’s children were

1 All future statutory references are to the Welfare and Institutions Code. 2 “[B]ecause ICWA uses the term ‘Indian,’ we do the same for consistency, even though we recognize that other terms, such as ‘Native American’ or ‘indigenous,’ are preferred by many.” (In re Benjamin M.…