Sacramento County Department of Health & Human Services v. Tammi G., 209 Cal. App. 4th 661

Tammi G. appeals a court order removing the minors Michael A. and Austin A. from her custody under Welfare and Institutions Code section 387.
Appellant argues ICWA inquiry/notice failures and improper delegation of visitation discretion to the Department.
Tribal affiliations alleged by appellant led the Department to send ICWA notices to several Cherokee and Creek tribes, with negative or no responses.
A periodic history shows appellant had de facto parent status since 2007, but the Department doubted she could qualify as a prospective adoptive parent or guardian.
In 2011, due to reports of neglect and concerns about care, a new permanent plan was ordered with a goal of legal guardianship, and petitions under section 387 were filed to remove the minors.
The juvenile court awarded visitation to appellant but delegated time/place/manner of visitation to the Department, who could decide on supervision and when to allow unsupervised visits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ICWA notice/inquiry standing to appeal	G. contends ICWA errors require review on appeal.	Department argues lack of standing and forfeiture bar review.	G. lacks standing; ICWA claim rejected without reaching merits.
Visitation order delegation	G. asserts improper delegation of visitation decisions to the Department.	Department argues the issue is forfeited for lack of objection.	Forfeited; visitation discretion affirmed as stated by the court.

In re S.M., 118 Cal.App.4th 1108 (Cal. Ct. App. 2004) (ICWA standing for grandparent/de facto parent analyzed)
In re J.B., 178 Cal.App.4th 751 (Cal. Ct. App. 2009) (ICWA standing implications for non-parents)
In re Patricia E., 174 Cal.App.3d 1 (Cal. Ct. App. 1985) (relative considerations in ICWA context)
Amato v. Mercury Cas. Co., 18 Cal.App.4th 1784 (Cal. Ct. App. 1993) (standing/claim presentation requirements on appeal)