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In re Layla C. CA2/7
APPEAL from an order of the Superior Court of Los Angeles County, Kristen Byrdsong, Juvenile Court Referee. Conditionally affirmed and remanded with directions.
Paul A. Swiller, under appointment by the Court of Appeal, for Defendant and Appellant.
Dawyn R. Harrison, Acting County Counsel, Kim Nemoy, Assistant County Counsel, for Plaintiff and Respondent.
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Marco C., the presumed father of two-year-old Layla C., appeals the November 17, 2021 order terminating his parental rights, arguing only that the Los Angeles County Department of Children and Family Services breached its affirmative and continuing duty to inquire whether Layla may have Indian ancestry as defined by the Indian Child Welfare Act of 1978 (ICWA) (25 U.S.C. § 1901 et seq.) and related California law. (Welf. & Inst. Code, § 224.2, subds. (a) & (b).) The Department acknowledges its compliance with its duty of inquiry may have been “imperfect,” but contends it made “painstaking efforts to com

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