In re Gabriel G

In In re Gabriel G. (2012) 206 Cal.App.4th 1160, the father indicated in the ICWA form that the paternal grandfather was a member of the Cherokee tribe, but when subsequently interviewed by the social worker, reportedly stated that he did not have Indian heritage. The report "did not provide any specifics regarding the inquiry the social worker made of father as to his Indian heritage . . . . Nor did the social worker state whether he specifically asked father to elaborate on the information provided in the ICWA-020 form or to explain any discrepancy between its contents and father's statement to the social worker." (Id. at p. 1167.) The court of appeal concluded that on the record, it was unclear what the father intended to convey, and that "having received conflicting information," both the social worker and the court had a duty to inquire further. (Id. at pp. 1167-1168.)