In re E.L. CA5
Jerry L. (father) appeals from the juvenile court’s order denying his Welfare and Institutions Code section 388 petition, by which he sought to reinstate his reunification services. Father contends the juvenile court abused its discretion in denying the petition without an evidentiary hearing. He also contends the juvenile court erred in failing to address whether active efforts were made to provide remedial services and rehabilitative programs designed to prevent the breakup of the Indian family, as required by the Indian Child Welfare Act (ICWA), 25 United States Code section 1901 et seq., and there is no substantial evidence to support an implied active efforts finding. We reject father’s contentions and affirm.
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