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In re K.M. CA2/5
K.W. (Mother) appeals from an order terminating parental rights over her daughter K.M. (Minor). We consider whether the juvenile court erred in declining to rely on the parental benefit exception to forego terminating Mother’s parental rights. In addition, we consider whether the Los Angeles County Department of Children and Family Services (the Department) had a duty under the Indian Child Welfare Act (ICWA) (25 U.S.C. § 1901 et seq.) and related California law to determine whether Minor’s alleged father (not presumed father) S.A. has any Indian heritage.

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