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Name: In re Charlotte V.
Case #: B269633
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 11/01/2016

ICWA notice was adequate where there was sufficient evidence of notice to the tribe. Mother appealed from a parental rights termination contending that the court failed to comply with ICWA’s strict notice requirements. Mother argued that the notices were deficient because they excluded all information about the minor’s grandmother except for her name, and excluded all information concerning the minor’s cousin and great-grandparents, all of whom had Indian ancestry. She argued that DCFS could have gotten information from the minor’s grandfather, uncle, and cousin, but failed to do so. The appellate court rejected her argument and affirmed. There is no requirement that information about non-lineal ancestors be provided. The record contained substantial evidence of ICWA compliance, including mother’s tribal identification card and number, as well as information about mother’s time on the reservation. It was unlikely that information about grandmother would establish the minor’s Indian ancestry when mother’s tribal identification card and member number did not.