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In re C.M. CA2/5
As the only issue raised in father’s appeal is ICWA
compliance, we focus on the facts and procedural background relevant to that issue.
1. Parents’ Dependency History
Both parents have a history with the dependency courts. Father’s three older children (by a different mother) became dependents in 2014 and 2016. In those cases, father filed a Parental Notification of Indian Status (ICWA-020) form, and the juvenile court found no reason to know that father’s children were Indian children as defined under ICWA. Proceedings were eventually terminated and a family law order provided their mother full custody.
In October 2017, DCFS filed a section 300 petition on behalf of mother’s older child (by another father), alleging mother and her male companion (father in the present case) engaged in domestic violence and mother abused drugs. In January 2018, the court sustained jurisdiction over the older child and removed the older child from mother’s custody. The court ordered reunificatio

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