California Supreme Court

In re Dezi C.

August 19, 2024

Summary

The court held that a child welfare agency's inadequate inquiry into whether dependent children may be Indian children requires conditional reversal of an order terminating parental rights. Because an inadequate inquiry leaves the record insufficient to determine prejudice, the matter must be remanded for a documented inquiry and, when required, notice under California's Indian Child Welfare Act provisions. If the juvenile court later finds that the inquiry was adequate and that the Act does not apply, it must reinstate the termination order.