In re J.L. CA2/3

── In re J.L. CA2/3 ── Court: California Court of Appeal Date: May 28, 2026 Category: General Filed 5/28/26 In re J.L. CA2/3 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION THREE B350102 In re J.L. et al., Persons Coming Under the Juvenile Court Law. (Los Angeles County Super. Ct. No. 21CCJP04668A–B) LOS ANGELES COUNTY DEPARTMENT OF CHILDREN AND FAMILY SERVICES, Plaintiff and Respondent, v. N.T., Defendant and Appellant. APPEAL from orders of the Superior Court of Los Angeles County, Terry T. Truong, Judge. Affirmed. Jacob I. Olson, under appointment by the Court of Appeal, for Defendant and Appellant.  Dawyn R. Harrison, County Counsel, Jacklyn K. Louie, Assistant County Counsel, Bryan Mercke, Deputy County Counsel, for Plaintiff and Respondent. ‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗‗ Appellant N.T. (mother) appeals from juvenile court orders terminating her parental rights over her two minor children, J.L. and A.L. Mother specifically argues that the Department of Children and Family Services (DCFS) failed to adequately inquire into the children’s Indian heritage on mother’s side, as required by the federal Indian Child Welfare Act (ICWA; 25 U.S.C. § 1901 et seq.) and related California law (Welf. & Inst. Code, § 224 et seq.).1 Father is not a party to this appeal, and mother does not argue that the ICWA inquiry on father’s side was inadequate. Accordingly, our analysis focuses on the ICWA inquiry on mother’s side. We affirm. FACTUAL AND PROCEDURAL BACKGROUND The juvenile court exercised jurisdiction over J.L. in December 2021, and over A.L. in August 2022. The court sustained petitions under section 300 alleging that both children were at risk of harm based on exposure to the parents’ domestic violence and father’s history of substance abuse, and declared the children dependents of the court. ICWA investigation in prior proceedings In early 2020, during a prior dependency proceeding involving mother, maternal grandmother and maternal 1 All further undesignated statutory references are to the Welfare and Institutions Code. 2 grandfather each filed a Parental Notification of Indian Status (ICWA-020) form stating, “I have no Indian ancestry as far as I know.”2 During a February 2020 pre-adjudication progress hearing, the juvenile court found no reason to know that mother was an Indian child.3 And in January 2022, maternal grandmother denied having any Indian ancestry. ICWA investigation in this proceeding In July and August 2021, mother denied that she or J.L. had any Indian heritage. Mother submitted an ICWA-020 form in October 2021 indicating that J.L., mother, and maternal grandparents were not eligible for membership in any federally recognized tribe. In February 2022, the court found that there was no reason to know J.L. was an Indian child, and in May 2022 it found that ICWA was not applicable to A.L. At the start of the underlying proceedings, mother and J.L. were living in a DCFS foster care placement with foster mother Theresa A.4 Mother began living with Theresa A.in 2019. DCFS 2 Through the ICWA-020 form, a parent in a dependency proceeding must provide information about the child’s Indian status. The form “is not intended to constitute a complete inquiry,” and it advises that a parent must disclose any subsequently discovered information relevant