In re Alexis H

In In re Alexis H. (2005) 132 Cal.App.4th 11, the appellate court primarily focused on whether the trial court had jurisdiction over the minors on any ground. Finding that the mother's conduct had endangered the children and was sufficient to establish jurisdiction, the court of appeal went on to note "be that as it may, appellant in any event admitted he was in prison for drug possession. While in prison, he cannot care for or supervise his children, rendering his imprisonment enough for the court to exercise jurisdiction under section 300 subdivision (b)." (132 Cal.App.4th at p. 16.) The juvenile court declared the children dependents, placed them with the mother, and ordered family maintenance services for her. It also granted monitored visitation and reunification services for father. (Alexis H., supra, 132 Cal.App.4th at p. 14.) The Court rejected father's argument that DCFS failed to comply with the ICWA notice requirements because "by its own terms, the act requires notice only when child welfare authorities seek permanent foster care or termination of parental rights; it does not require notice anytime a child of possible or actual Native American descent is involved in a dependency proceeding." (Alexis H., at p. 14.)