In re Y.C. CA4/2, E084538

The San Bernardino County juvenile court terminated D.C.'s parental rights regarding his child, Y.C., following dependency proceedings initiated due to the mother's substance abuse and unstable home environment.
Throughout the dependency proceedings, both parents and numerous extended family members repeatedly denied any Native American ancestry, relevant for the Indian Child Welfare Act (ICWA).
The Department made extensive and repeated inquiries into both maternal and paternal family members' Native American ancestry, including direct inquiries in court and attempts to contact additional relatives.
Some extended family members could not be reached, but the Department made multiple reasonable efforts (phone calls, voicemails, text messages) to inquire.
The juvenile court made multiple findings that ICWA did not apply after hearing evidence of these inquiries at several stages.
On appeal, D.C. (father) argued that the Department's efforts to inquire with certain paternal relatives were insufficient under ICWA and California ICWA (Cal-ICWA). The appellate court affirmed the juvenile court's termination of parental rights and finding that ICWA did not apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Department complied with its ICWA duty of inquiry	Social Services argued it consistently and adequately inquired with all reasonably available relatives about Indian ancestry	D.C. argued that the Department failed to adequately inquire of certain extended paternal family members and one in-law	The Department satisfied its duty of inquiry under ICWA and Cal-ICWA; the orders are affirmed

In re Dezi C., 16 Cal.5th 1112 (Cal. 2024) (affirming the agency and court's duty to make reasonable inquiry regarding ICWA; sets out standards for what constitutes reasonable diligence)
In re Kenneth D., 16 Cal.5th 1087 (Cal. 2024) (clarifies scope and discretion of juvenile courts in determining adequacy of ICWA inquiry)