In re K.L.

── In re K.L. ── Court: California Court of Appeal Date: May 29, 2026 Category: General Filed 5/18/26; Certified for Publication 5/29/26 (order attached) IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION EIGHT In re K.L., a Person Coming B348185 Under the Juvenile Court Law. ______________________________ Los Angeles County LOS ANGELES COUNTY Super. Ct. No. 20CCJP03930 DEPARTMENT OF CHILDREN AND FAMILY SERVICES, Plaintiff and Respondent, v. J.A., Defendant and Appellant. APPEAL from the findings and order of the Superior Court of Los Angeles County, Juan M. Valles, Juvenile Court Referee. Affirmed. Joseph T. Tavano, under appointment by the Court of Appeal, for Defendant and Appellant. Dawyn R. Harrison, County Counsel, Kim Nemoy, Assistant County Counsel, and Navid Nakhjavani, Deputy County Counsel, for Plaintiff and Respondent. _______________________  INTRODUCTION Father J.A. challenges termination of his parental rights to his son K.L. pursuant to Welfare and Institutions Code 1 section 366.26. He asks us to conditionally reverse and remand the matter because the Los Angeles County Department of Children and Family Services (DCFS) did not satisfy its initial duty of inquiry to ascertain whether there was reason to believe K.L. had Indian ancestry. Specifically, Father contends that because DCFS failed to interview maternal grandmother, its inquiry did not satisfy the demands of the Indian Child Welfare Act of 1978 (ICWA), (25 U.S.C. § 1901 et seq.) and its California counterpart (§ 224.2 et seq.). We affirm. A. Procedural Background On July 24, 2020, DCFS filed a petition pursuant to section 300 on behalf of four-year-old K.L. and his four older half- siblings. (The half-siblings are not involved in this appeal so we will not further discuss their cases.) The petition alleged the children were at substantial risk of physical harm because Mother had a history of illicit drug abuse, was a daily user of methamphetamine and amphetamine, and had tested positive for those drugs on July 15, 2020. It also alleged that on prior occasions Mother was under the influence of illicit drugs while the children were under her care and supervision. On July 29, 2020, the court detained K.L. from his mother. K.L. was placed with his half-siblings at the home of their maternal aunt. 1 Further undesignated statutory references are to the Welfare and Institutions Code. 2  At the jurisdictional hearing on September 18, 2020, neither parent appeared. Their whereabouts were unknown. The court sustained the petition, declared K.L. a dependent of the juvenile court, removed him from Mother’s custody, ordered him suitably placed, and ordered monitored visitation and reunification services for Mother. Mother made her first appearance at the six-month review hearing on March 18, 2021. She was eight months pregnant. The review was continued to April 9, 2021. The court continued reunification services for Mother. Mother gave birth on June 2, 2021. The baby tested positive for amphetamines, was detained and placed with her siblings in the home of the maternal aunt. At the 12-month review hearing on October 27, 2021, neither parent appeared. Parents’ whereabouts were unknown. The juvenile court found that Mother’s progress with her case plan had not been substantial; it terminated reunification services and set the matter for a permanency planning hearing pursuant to section 366.26. As of April 27, 2022, Mother’s whereabouts were still unknown, although the social worker had a new cell phone number for her. On May 13, 2022, Father made his first appearance and on July 6, 2022, the court ordered paternity testing which showed Father is K.L.’s biological parent. On October 26, 2022, the court found Father was K.L.’s b