Parental Notification of Indian Status

In In re Cheyanne F. (2008) 164 Cal.App.4th 571, the parents submitted their parental notification of Indian status forms. The mother stated that she was not aware of any Indian ancestry. The father claimed that he was a registered member of the Blackfeet Tribe. ICWA notice was sent. The notice, however, only included the father's ancestry, and did not contain information concerning the mother and the names of her relatives. (Id. at p. 574.) The mother appealed from an order terminating her parental rights and contended that the juvenile court's finding that ICWA did not apply was erroneous because the agency omitted required information. (Cheyanne F., supra, 164 Cal.App.4th at p. 573.) The mother claimed that the juvenile court's ruling was erroneous because the agency failed to perform its mandatory duty to provide the tribe with her place of birth, and the names of her parents and grandparents. She pointed out that her place of birth and names of her parents were known to the agency. (Ibid.) In Cheyanne F., supra, 164 Cal.App.4th 571, we determined that an ICWA notice must "contain enough information to permit the tribe to conduct a meaningful review of its records to determine the child's eligibility for membership." (Id. at p. 576.) The Court also found that, "in the absence of any indication that information concerning the mother's family was relevant to the tribe's inquiry, there is no basis upon which to conclude that the outcome would have been different if DPSS had provided the mother's place of birth and the information concerning her parents and grandparents." (Id. at p. 577.) The Court therefore concluded that the mother failed to show that any omission was prejudicial. We affirmed the order terminating parental rights. (Id. at pp. 573, 579.)