In re Antoinette S

In In re Antoinette S. (2002) 104 Cal.App.4th 1401, the mother first claimed that neither she nor the father had Indian heritage, at which point the dependency court held that the ICWA did not apply. Father later told the social worker that he may have Indian ancestry from his maternal grandparents, but was unable to provide a specific tribe or specific information about his maternal grandparents. On appeal, the father argued that the ICWA's notice requirements were triggered by his statement and that the notice sent by the Department was insufficient to meet those requirements. (Id. at pp. 1404-1405.) Applying the low threshold and minimal showing required to invoke the ICWA's notice requirements, the appellate court held that "father's suggestion that the child 'might' be an Indian child was enough to trigger notice in this case." (Id. at p. 1408.)