In re M.A. CA2/4

Filed 11/20/25 In re M.A. CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FOUR

In re M.A., a Person Coming B341383 Under the Juvenile Court Law. (Los Angeles County Super. Ct. Nos. 22CCJP04164, 22CCJP04164A ) LOS ANGELES COUNTY DEPARTMENT OF CHILDREN AND FAMILY SERVICES,

Plaintiff and Respondent. v. E. A.,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Cathy J. Ostiller, Judge. Reversed and remanded with instructions.

Jack A. Love, under appointment by the Court of Appeal for Defendant and Appellant. Dawyn R. Harrison, County Counsel, Kim Nemoy, Assistant County Counsel, Veronica Randazzo, Deputy County Counsel, for Plaintiff and Respondent.

MEMORANDUM OPINION1 Appellant E.A. (mother) challenges the juvenile court’s order terminating her parental rights with respect to her daughter, M.A. Her sole contention is that the juvenile court and respondent Los Angeles County Department of Children and Family Services (DCFS) failed to comply with the inquiry requirements of the Indian Child Welfare Act (25 U.S.C. § 1901 et seq.) (ICWA) and related California law. We agree and conditionally reverse and remand. DISCUSSION I. Legal Principles ICWA and related California law2 reflect “a congressional determination to protect Indian children and to promote the

1 We resolve this case by memorandum opinion. (Cal. Stds. Jud. Admin., § 8.1.) We do not recite the factual and procedural background because our opinion is unpublished and the parties are familiar with the facts of the case and its procedural history. (People v. Garcia (2002) 97 Cal.App.4th 847, 851 [unpublished opinion merely reviewing correctness of trial court’s decision “does not merit extensive factual or legal statement”].) Undesignated statutory references are to the Welfare and Institutions Code. 2 The Legislature incorporated ICWA’s requirements into California law in 2006. (In re Abbigail A. (2016) 1 Cal.5th 83, 91.)