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In re T.N. CA4/2
L.N. (mother) appeals from the juvenile court’s order at the six-month review hearing. She argues there was insufficient evidence to support the findings (1) she received reasonable reunification services as to her teenage daughter, T.N., and (2) the Indian Child Welfare Act (ICWA) did not apply.
The juvenile court removed T.N. from mother based on mother’s addiction to prescription pain killers and mental health issues. Early in the case, mother told the social worker she was a carrier of MRSA, a bacterial infection that is highly contagious and difficult to treat. Based on her representation, the court ordered mother to obtain medical clearance before visiting her daughter or beginning services. Over the next seven months, mother repeatedly promised clearance was forthcoming while simultaneously showing no interest in visitation or services.

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