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In re Julian G. CA3
Emily E. (mother) and Carlos G. (father) appeal from the juvenile court’s order terminating parental rights for their child, Julian G. (the minor). (Welf. & Inst. Code, § 366.26; unless otherwise set forth, statutory section citations that follow are to the Welfare and Institutions Code.) Mother and father each contend the San Joaquin County Human Services Agency (Agency) failed to comply with the inquiry and notice procedures of the Indian Child Welfare Act (ICWA). (25 U.S.C. § 1901 et seq.) Mother also contends the juvenile court erred in (a) denying mother’s section 388 modification petition without a hearing, and (b) failing to find the beneficial parental relationship exception applied. (§ 366.26, subd. (c)(1)(B)(i).) Agreeing with the claim of ICWA error only, we reverse and remand for proper inquiry and notice.

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