Dec. 14, 2022 – In re Adrian L. (2nd Dist., 1st Div., B318627)

The Court of Appeal finds that in reviewing the record as a whole, it is unlikely that unquestioned extended family members would have information that would have borne meaningfully on the question of whether the child was an Indian child. The court thus holds that ICWA-inquiry error under WIC 224.2(b) was harmless. The concurring opinion reviews the statutory obligation and argues for a narrow construction of the duty to inquire under subdivision (b).