Agency did not need to duplicate efforts to inquire with Minor’s maternal family regarding heritage for the Indian Child Welfare Act (ICWA) where the juvenile court found ICWA did not apply in Mother’s case a year earlier. Mother became a dependent of the juvenile court in 2020. Mother and maternal grandmother denied Indian ancestry and the juvenile court found ICWA did not apply. Less than a year later, Mother’s child, C.R., was removed from Mother, who continued to deny any Indian ancestry. Father also denied Indian ancestry. Mother appealed the termination of her parental rights, raising ICWA initial inquiry compliance as the sole issue on appeal and the reviewing court affirmed. Because the Agency had already inquired with maternal grandmother in Mother’s case and found that ICWA did not apply to Mother, the juvenile court could reasonably conclude there was no reason to duplicate efforts as to Mother’s side of the family by asking maternal grandmother again about Indian ancestry. Further, since maternal grandmother denied Indian ancestry, the court could reasonably conclude that asking maternal aunt and cousin was unnecessary as they were unlikely to have more information about ancestry than maternal grandmother.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/B341335.PDF