In re K.C. CA2/3
── In re K.C. CA2/3 ──
Court: California Court of Appeal
Date: June 05, 2026
Category: General
Filed 6/5/26 In re K.C. CA2/3
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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
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION THREE
In re K.C. et al., Persons Coming B345186
Under the Juvenile Court Law.
Los Angeles County
LOS ANGELES COUNTY Super. Ct. Nos.
DEPARTMENT OF CHILDREN 22CCJP00042A,
AND FAMILY SERVICES, 22CCJP00042B,
22CCJP00042C
Plaintiff and Respondent,
v.
T.J.,
Defendant and Appellant.
APPEAL from an order of the Superior Court of
Los Angeles County, Ashley Price, Judge. Affirmed.
Elizabeth C. Alexander, under appointment by the
Court of Appeal, for Defendant and Appellant.
Dawyn R. Harrison, County Counsel, Kim Nemoy,
Assistant County Counsel, and Bryan Mercke, Deputy
County Counsel, for Plaintiff and Respondent.
_________________________
Mother challenges the adequacy of notices the Los Angeles
County Department of Children and Family Services
(Department) sent to the Bureau of Indian Affairs (BIA) and
specific tribes in connection with her children’s dependency cases.
She contends the Department’s failure to comply with the federal
Indian Child Welfare Act (ICWA; 25 U.S.C. § 1901 et seq.) and
related California law (Welf. & Inst. Code, § 224 et seq.) requires
reversal of the juvenile court’s ICWA findings and remand with
instructions regarding the notices.1 We conclude the evidence
supports the court’s ICWA findings and formal notice was not
required. We affirm.
BACKGROUND
The sole issue raised in Mother’s appeal is ICWA
compliance. We therefore focus on the facts bearing on this issue.
Mother has three boys: K.C. (born December 2019); S.B.
(born February 2022); and R.B. (born November 2022). A.P.
(Father P.) is K.C.’s presumed father. Ri.B. (Father B.) is the
presumed father of S.B. and R.B.
The Department filed dependency petitions, alleging
Mother and Father B. had a history of domestic violence that
endangered the children. A later petition added allegations that
Mother neglected the children. The juvenile court sustained
the petitions and declared the children dependents.
1. Initial ICWA Inquiries
Mother and Father B. each filed ICWA-020 forms for S.B.
and R.B. stating the children had no known Indian ancestry.
At the initial detention hearing for S.B., the court reviewed the
1 State statutory references are to the Welfare and
Institutions Code.
2
parents’ ICWA-020 forms and found there was no reason to know
S.B. was an Indian child. At an early hearing for R.B., the
court asked Father B. about the child’s possible Indian status.
Father B. denied any Indian ancestry. Based on the parents’
ICWA-020 forms and the inquiry of Father B., the court found
there was no reason to know R.B. was an Indian child.
As for K.C., Mother filed an ICWA-020 form stating the
child has no known Indian ancestry. At the initial detention
hearing, the juvenile court reviewed the form and found ICWA
did not apply to K.C. through Mother. The court also found
Father P.—whose whereabouts were unknown—to be K.C.’s
alleged father. After the Department completed its due diligence
without locating Father P., the court made an initial finding
that it had no information to believe ICWA applied to
{# E23 (Nick, ruling section 1 answer 10): quoting a bill or a court opinion works
the way quoting a news article works. Select a passage above and the same panel
opens: the passage goes to the official you choose, with this document's own
address as its source and its own type. #}