Jun. 30, 2022 – In re E.V. (4th Dist., Div. 3, G061025)

The Court of Appeal finds that the juvenile court and the Department failed to adequately inquire into the child’s Indian ancestry as required by ICWA. The court reiterates that the appellate court is not the appropriate venue for determining if the Department’s postjudgment investigation was adequate. The court concludes that conditional reversal is required to ensure the tribes’ interests are considered and protected.