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In re Layla S. CA2/17
S.S. (father) and T.J. (mother), parents of the minor, appeal from the juvenile court’s order terminating parental rights and freeing the minor for adoption. (Welf. & Inst. Code, §§ 366.26, 395; statutory section references that follow are found in the Welfare and Institutions Code.) The parents contend the juvenile court failed to apply the correct standard of proof -- beyond a reasonable doubt -- at the selection and implementation hearing given that the minor is an Indian child within the meaning of the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.). The Sutter County Department of Human Services (Department) argues the parents failed to object and therefore forfeited their claim on appeal.

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