In re Ricky R.
Annotate this CaseN.G. (Mother) appealed a juvenile court’s order terminating parental rights to her children, Ricky R. and Jayden R. Mother argued the Riverside County Department of Public Social Services (DPSS) failed to discharge its duty of initial inquiry under state law implementing the federal Indian Child Welfare Act of 1978 (ICWA). DPSS did not dispute that it failed to discharge its duty of initial inquiry, but it argued that the error was harmless. DPSS also moved to dismiss the appeal as moot on the basis of postjudgment evidence, and it asked the Court of Appeal to consider that evidence under several theories. After review, the Court concluded DPSS prejudicially erred by failing to comply with its duty of initial inquiry under ICWA-related state law. The Court also denied DPSS’s motion to dismiss the appeal and declined to consider the postjudgment evidence of ICWA inquiries conducted while this appeal was pending. To this end, the Court held the juvenile court should consider that evidence in the first instance and determine whether DPSS discharged its duties under ICWA and related state law.
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