In re L.S.
Annotate this CaseJ.S. (mother) and L.S. (father), appealed juvenile court orders denying their petitions for modification and terminating parental rights to their minor children. The parents argued the court applied the wrong burden of proof in denying their petitions for modification and abused its discretion in concluding there was insufficient evidence to grant the requested modification. The parents also contend the court and the El Dorado County Health and Human Services Agency (Agency) failed to comply with the notice requirements of the Indian Child Welfare Act (ICWA). Finally, the parents argued the court erred in failing to find they had established the beneficial parental relationship exception to termination of parental rights. The Court of Appeal concluded that the juvenile court’s failure to apply the proper burden of proof in ruling on the petitions for modification and the errors in the ICWA notice required reversal.
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