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Name: In re P.R.
Case #: C077293
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 05/12/2015

Mother lacked standing to appeal placement of Indian minor where she did not otherwise challenge the termination of her parental rights. Mother appealed from the order terminating her parental rights, contending that substantial evidence did not support the juvenile court’s finding that there was good cause to deviate from the ICWA placement preferences. However, mother did not argue that her parental rights were wrongly terminated. The appellate court dismissed mother’s appeal, holding that because her parental rights were terminated, and she makes no argument as to how alleged placement errors might be related to the termination decision, mother lacked standing to challenge placement matters. Although mother had standing to raise other issues relating to the ICWA, such as notice and inquiry where the ICWA issues could impact the termination order, on the sole issue raised here, mother lacked standing to appeal.