In re R.S. CA4/2
Mother and father appeal orders which led to the termination of their parental rights over their son, who was three months old at the time he was removed due to serious physical abuse. Mother argues the trial court erred when it determined (i) she did not establish a change of circumstances to justify giving her reunification services (Welf. & Inst. Code, § 388, unlabeled statutory citations refer to this code) and (ii) the parent-child relationship did not outweigh the benefits of adoption. (§ 366.26, subd. (c)(1)(B)(i).)
Father appeals the trial court’s ruling that ICWA does not apply to the child. He argues the trial court’s finding that San Bernardino County Children and Family Services (the department) provided adequate notice to the tribes is not supported by substantial evidence. He says the department’s notice was faulty because they spelled his maternal grandmother’s name as “Cathleen Jordan” rather than “Kathleen Jordan.”
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