Mar. 16, 2022 – In re Antonio R. (2nd Dist., Div. 7, B314389)

In an appeal from the termination of parental rights, the Court of Appeal finds that the Department failed to make an adequate initial inquiry as required under WIC 224.2, and that the juvenile court erred in making a finding that ICWA did not apply. The Court of Appeal notes that the juvenile court’s error was prejudicial because, in most circumstances, the information in possession of extended relatives is likely to be meaningful in determining whether the child is an Indian child, regardless of whether the information ultimately shows the child is or is not an Indian child.