Filed 3/28/23 In re L.L. CA2/1

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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

In re L.L., A Person Coming Under 

the Juvenile Court Law.

_________________________________

LOS ANGELES COUNTY 

DEPARTMENT OF CHILDREN 

AND FAMILY SERVICES,

Plaintiff and Respondent,

v.

LISA L.,

Defendant and Appellant.

 B318779, B320802

 (Los Angeles County

 Super. Ct. No. 18CCJP06654A)

APPEAL from orders of the Superior Court of Los Angeles 

County, Debra R. Archuleta, Judge. Affirmed.

Jill Smith, under appointment by the Court of Appeal, 

for Defendant and Appellant.

Dawyn R. Harrison, Interim County Counsel, Kim Nemoy, 

Assistant County Counsel, and William D. Thetford, Principal 

Deputy County Counsel, for Plaintiff and Respondent.
2

Lisa L. (Mother) appeals from the juvenile court’s January 18,

2022 order denying her Welfare and Institutions Code section 3881

petition without a hearing. Through the petition, Mother sought 

custody of her then four-year-old daughter, L.L., or alternatively, 

six additional months of reunification services and liberalized 

visitation. Mother contends that the court erred in summarily 

denying her petition because she made a prima facie showing of 

changed circumstances, including her enrollment in a residential 

substance abuse treatment program, and that the proposed order 

would be in L.L.’s best interests. Mother contends further that 

the Department of Children and Family Services (DCFS) and the 

juvenile court failed to discharge their respective initial inquiry 

duties under California law implementing the Indian Child Welfare 

Act (ICWA) (25 U.S.C. § 1901 et seq.), and that these failures 

require reversal of the court’s finding that ICWA does not apply in 

this case. Specifically, Mother argues that DCFS failed to interview 

available extended family members concerning L.L.’s heritage, and 

that the court failed to instruct the parties on the record that they 

must disclose any subsequently obtained information relevant to 

the ICWA inquiry.

Mother also appeals the juvenile court’s March 22, 2022

orders appointing paternal grandmother and paternal 

great-grandmother as L.L.’s legal guardians and terminating 

dependency jurisdiction, relying exclusively on her claims

concerning the section 388 petition and alleged ICWA errors as 

grounds for reversal.

We agree that Mother has made laudable progress in 

alleviating the concerns that gave rise to this case. The record

1 Unless otherwise specified, subsequent statutory references 

are to the Welfare & Institutions Code.
3

discloses, however, that much of that progress occurred after 

the juvenile court denied Mother’s section 388 petition. Mother is 

free to file a new petition detailing her additional progress, but we 

cannot conclude that the court abused its discretion in summarily 

denying the January 2022 petition on the then-existing record. 

We conclude further that the ICWA inquiry errors alleged here 

were harmless. Accordingly, we affirm the juvenile court’s orders.

FACTUAL AND PROCEDURAL SUMMARY2

A. Overview

On October 10, 2018, law enforcement arrested Mother 

for walking in the middle of traffic backwards while holding

then 10-month-old L.L. The officers hospitalized Mother

pursuant to section 51503 and placed L.L. in the care of her 

father, C.W. (Father). On October 16, 2018, DCFS filed a 

section 300 petition concerning L.L. alleging that Mother’s 

“mental and emotional problems”—which included a diagnosis 

of schizoaffective and bipolar disorders—and her purported abuse 

of marijuana and benzodiazepine placed L.L. at risk of serious 

2 We limit our summary to the facts and procedural 

history relevant to the issues Mother raises on appeal. Father 

is not a party to this appeal, and we therefore discuss his 

involvement in the dependency proceedings only to the extent 

relevant to Mother’s claims.

3 Section 5150 authorizes law enforcement to take into 

custody for up to 72 hours “a person [who], as a result of a 

mental health disorder, is a danger to others, or to themselves.” 

(§ 5150.) Law enforcement previously had placed Mother on 

a section 5150 hold on September 26, 2018, because she had

“active suicidal thoughts.” The hospital prescribed Mother 

medication and discharged her on October 8, 2018, two days 

prior to the October 10, 2018 incident.
4

physical harm. The following day, the juvenile court held a 

detention hearing at which it ordered L.L. to remain in Father’s 

care and granted Mother monitored visitation.

At the subsequent December 6, 2018 jurisdiction hearing, 

the court dismissed the petition’s allegations concerning Mother’s

drug abuse, but sustained the allegations concerning Mother’s 

mental health issues. The court also issued a case plan for Mother 

requiring that she participate in parenting education, individual 

counseling, and a psychiatric evaluation; take all prescribed 

psychotropic medication; and submit to 10 random drug tests, 

with a full treatment program upon a missed or positive test.4

On March 29, 2019, the juvenile court authorized L.L.’s 

removal from Father, in response to allegations that he was abusing 

marijuana and had permitted Mother to have unmonitored contact 

with L.L. On April 2, 2019, DCFS filed a supplemental petition 

pursuant to section 387 on the basis of these allegations. At the 

subsequent April 3, 2019 hearing, the juvenile court approved 

DCFS’s placement of L.L. in the care of paternal grandmother 

and paternal great-grandmother. L.L. remained in that placement 

throughout the ensuing dependency proceedings.

At the November 5, 2019 six-month status review hearing,

the juvenile court found that Mother had not made substantial 

progress with her case plan. Although Mother had enrolled in an 

outpatient substance abuse program, she attended only sporadically 

and continued using marijuana. She was not consistent in 

submitting to random drug testing. In addition, Mother had failed 

to participate in individual counseling for the month leading up to 

4 Although the juvenile court reissued Mother’s December 6, 

2018 case plan on May 14, 2019, the court did not materially alter

the plan’s terms.
5

the hearing, and Mother’s therapist reported that she did not 

appear to be making progress in her treatment goals. Finally, 

notwithstanding Mother’s completion of a parenting class and her 

twice-weekly visits with L.L., Mother told DCFS that “she was not 

ready for [L.L.] to return to her care because [she was] ‘tired.’ ” The 

juvenile court therefore ordered further reunification services and 

set the 12-month review hearing for May 5, 2020. Due in part to 

the Covid-19 pandemic, the court continued the 12-month review

hearing to December 8, 2020.

At the December 8 hearing, the juvenile court again found

that Mother’s compliance with her case plan “ha[d] been below 

adequate.” Since the six-month status review, Mother had

demonstrated improved consistency in participating in mental 

health services and increased motivation to comply with her

medication regimen; however, she sometimes forgot to take 

her prescriptions. Mother reliably participated in outpatient 

substance abuse counseling sessions, but she did not comply

consistently with the drug testing portion of the program. And 

although Mother continued to visit L.L., she did so less frequently—

visiting only once per week, rather than the four times per week

permitted—and did not always appear for scheduled visits. The

court therefore concluded that it “[did not] think that [there was]

a likely date [by] which the child may be returned and safely

maintained in the family home,” and ordered that L.L. “continue 

in the out-of-home placement” with paternal grandmother 

and paternal great-grandmother. The court then terminated 

reunification services and set a section 366.26 hearing for 

March 30, 2021. The court subsequently continued the 

section 366.26 hearing several times due to changes in L.L.’s 

recommended permanent plan, finally scheduling the hearing 

for March 2, 2022.
6

On December 1, 2021, approximately four months prior 

to the scheduled March 2, 2022 section 366.26 hearing, Mother 

entered residential substance abuse treatment. Due to the 

Covid-19 pandemic, the program limited Mother’s visitation with 

L.L. to video chat. Mother participated in 15-minute video visits 

with L.L. four times during the week and occasionally on weekends. 

DCFS reported that the visits went well.

On January 11, 2022—while living at the residential 

treatment center—Mother filed a section 388 petition requesting 

that the juvenile court either return L.L. to Mother’s care or 

grant six additional months of reunification services, along with 

liberalized visitation. In support of her requests, Mother argued 

that her circumstances had changed because “[i]n addition to 

previously completing a parenting program . . . , [she] ha[d] been 

receiving mental health treatment . . . , outpatient substance 

use treatment . . . since 5/22/2020 . . . , and subsequently enrolled 

in an inpatient treatment program.” Mother argued further

that she “ha[d] been able to decrease her depressive symptoms 

with utilizing coping skills over the past year[,] . . . ha[d] made 

progress in treatment[,] and [had] obtain[ed] employment on her 

own.” Mother also noted that her “marijuana use ha[d] decreased 

consistently.” Finally, Mother asserted that her history of 

successful once-a-week visits with L.L. demonstrated that the 

requested relief would be in the child’s best interests.

On January 18, 2022, the juvenile court denied the petition, 

concluding that Mother had failed to make a prima facie showing 

of changed circumstances or that the proposed order would be in 

L.L.’s best interests.

Between the January 18 denial of her petition and the 

scheduled March 2 section 366.26 hearing, Mother completed 

60 days of residential substance abuse treatment. Following her 
7

release from the treatment facility on January 29, 2022, Mother 

began visiting L.L. Monday through Friday for three hours in the 

evening. DCFS reported that the visits went well: Mother would 

take L.L. to the park, help L.L. with homework, or do arts and 

crafts projects with L.L.

At the March 2, 2022 hearing, Mother introduced six exhibits 

reflecting, inter alia, her completion of residential substance abuse 

treatment, as well as her substantial volunteer service and positive 

participation as an “elder” in the residential program. The juvenile 

court determined that it could not order a permanent plan for L.L.

at the hearing because the materials submitted by DCFS did not 

adequately document the caregivers’ recent decision to pursue 

legal guardianship of L.L., rather than adoption.5 The court 

therefore continued the section 366.26 hearing to March 22, 2022. 

The court did, however, grant in part Mother’s request to allow 

her unmonitored visits with L.L., permitting two of Mother’s four 

weekly visits to proceed unmonitored.

On March 22, 2022, the juvenile court held the continued 

section 366.26 hearing. Mother objected orally to DCFS’s proposed 

plan of legal guardianship. She also requested that, if the court 

nonetheless granted guardianship, she be permitted to conduct 

all visits with L.L. unmonitored and be granted overnight visits. 

Mother did not, however, file a new section 388 petition in advance 

of the hearing. The juvenile court granted legal guardianship of 

5 The record discloses that paternal grandmother and 

paternal great-grandmother vacillated between pursuing adoption 

and legal guardianship. They explained that, originally, they

believed they must pursue adoption to prevent another family 

from adopting L.L. Their ultimate preference, however, was 

to pursue legal guardianship to allow Mother and Father the

possibility of reunifying with L.L. in the future.
8

L.L. to paternal grandmother and paternal great-grandmother. It 

also granted Mother’s request for unmonitored visits and granted 

discretion to L.L.’s legal guardians to permit overnight visits. 

Finally, the court terminated dependency jurisdiction over L.L.

B. ICWA Proceedings

Throughout the underlying dependency proceedings, Mother 

and Father represented repeatedly that they have no Native 

American Indian heritage. The ICWA Child Inquiry Attachment 

(Judicial Council Forms, form ICWA-010(A) (ICWA-010(A) form)) 

appended to the October 16, 2018 section 300 petition reflects that 

a DCFS social worker interviewed Father and Mother prior to 

the petition’s filing, and that both parents “denied ICWA” in those 

interviews.

In addition, both parents submitted parental notification 

of Indian status forms in which they checked the box indicating 

that they “have no Indian ancestry as far as [they] know” (Judicial 

Council Forms, form ICWA-020). The juvenile court also confirmed 

on the record during the October 17, 2018 detention hearing—at 

which both Mother and Father appeared—that “both parents 

indicate no Native American ancestry.”

Based on this information, the juvenile court determined

that it “[did] not have a reason to know” that L.L. was “an Indian 

[c]hild, as defined under ICWA, and [did] not order notice to any 

tribe or the [Bureau of Indian Affairs].” The court’s October 17, 

2018 minute order directed the parents “to keep [DCFS], their

[a]ttorney[s,] and the [c]ourt aware of any new information relating 

to possible ICWA status.” The court did not, however, inform the 

parents orally during the October 17 hearing of the requirement to

provide updated ICWA information.
9

On April 2, 2019, in connection with preparation of its 

supplemental section 387 petition, DCFS again interviewed 

Father concerning any known Indian ancestry. The ICWA-010(A) 

form appended to the supplemental petition reflects that, during 

the interview, Father reiterated his prior representation that L.L. 

“has no known Indian ancestry.” And on December 8, 2020, the 

juvenile court confirmed its prior finding that there was no reason 

to know that L.L. was an Indian child, as defined under ICWA.

Finally, the record reflects that, over the course of the

dependency proceedings, DCFS had contact with extended maternal 

and paternal relatives, including paternal grandmother, paternal 

great-grandmother, paternal grandfather, maternal grandmother, 

maternal aunt, and maternal uncle. DCFS concedes that it did not 

interview these relatives concerning L.L.’s heritage.

C. Notices of Appeal 

Mother timely appealed the juvenile court’s January 18, 2022

denial of her section 388 petition, as well as the court’s March 22, 

2022 orders appointing legal guardians for L.L. and terminating 

dependency jurisdiction. We consolidated the appeals for purposes 

of argument and decision.

6

6 In its respondent’s brief filed prior to the consolidation, 

DCFS argues that Mother’s purported failure to appeal the 

March 22, 2022 orders rendered moot the remainder of her 

appeal. DCFS now appears to recognize that Mother did appeal 

the March 22 orders, and it omits the mootness argument from 

its post-consolidation respondent’s brief. To avoid any doubt, we 

note that Mother’s appeals are not moot. We can provide Mother 

effective relief by (1) reversing the January 18 and March 22 

orders, and (2) directing the juvenile court to hold a hearing on 

the section 388 petition, to order further ICWA compliance, or 
10

DISCUSSION

Mother contends that we must reverse the juvenile court’s 

March 22, 2022 orders appointing legal guardians for L.L. and 

terminating dependency jurisdiction because (1) the court erred 

in denying her section 388 petition without a hearing, and 

(2) DCFS and the court failed to discharge their respective ICWA 

initial inquiry duties. Mother contends further that, in light of 

these errors, we must reverse the court’s January 18, 2022 order 

denying the section 388 petition and remand the matter for ICWA

compliance.

We review the court’s summary denial of the section 388 

petition for abuse of discretion (In re Angel B. (2002) 97 Cal.App.4th

454, 460), and because the material facts are undisputed, “ ‘ “we 

review independently whether ICWA requirements have been 

satisfied.” ’ [Citation.]” (In re J.K. (2022) 83 Cal.App.5th 498, 504.)

A. The Juvenile Court Acted Within Its Discretion 

When It Summarily Denied Mother’s Section 388 

Petition

Mother contends that the court abused its discretion by 

denying her section 388 petition without a hearing. We disagree. 

Section 388 allows a parent or other person with an interest 

in a dependent child to petition the court for a hearing to change, 

modify, or set aside any previous order on the grounds of change of 

circumstance or new evidence. (§ 388.) The petition “shall set forth 

in concise language any change of circumstance or new evidence 

both. (See, e.g., In re D.P. (2023) 14 Cal.5th 266, 277 [“[A] case is 

not moot where a court can provide the plaintiff with ‘ “effective 

relief.” ’ [Citation.] In this context, relief is effective when it ‘can 

have a practical, tangible impact on the parties’ conduct or legal 

status.’ ”].)
11

that is alleged to require the change of order or termination of 

jurisdiction.” (Ibid.) 

The parent seeking modification must “ ‘make a prima facie 

showing to trigger the right to proceed by way of a full hearing. 

[Citation.]’ [Citations.]” (In re Anthony W. (2001) 87 Cal.App.4th 

246, 250.) This showing has two prongs: A parent must 

demonstrate (1) a genuine change of circumstances or new evidence, 

and (2) that revocation of the prior order would be in the best 

interests of the child. (Ibid.) “The prima facie requirement is not 

met unless the facts alleged, if supported by evidence given credit 

at the [requested] hearing, would sustain a favorable decision on 

the petition.” (In re Zachary G. (1999) 77 Cal.App.4th 799, 806.)

Mother failed to make the necessary showing. With respect 

to the first prong, the record as a whole reflects that Mother 

was in the process of changing at the time the court denied her 

petition, not that she had completed a significant change. (See 

In re Mickel O. (2011) 197 Cal.App.4th 586, 615 [“the [section 388]

petitioner must show changed, not changing, circumstances,”

italics omitted].) Although Mother had obtained employment 

and demonstrated improved consistency in managing her mental 

health, she had entered residential substance abuse treatment 

only six weeks prior to filing her petition and had not yet completed 

the program. Mother’s laudable progress thus reflected changing, 

rather than changed, circumstances—a fact that distinguishes 

her case from the authorities on which she relies. (See In re N.F.

(2021) 68 Cal.App.5th 112, 119 [affirming juvenile court’s decision 

to conduct section 388 hearing, but ultimately to deny the petition, 

where petitioner had completed a 90-day residential treatment 

program five months prior to filing the petition]; In re Aljamie D.

(2000) 84 Cal.App.4th 424, 432 [reversing denial of section 388 

petition without a hearing because, inter alia, petitioner had tested 
12

clean in weekly random drug tests for over two years prior to 

filing the petition].)

As to the second prong, Mother relies solely on her 

once-a-week, in-person visits with L.L. as evidence that her 

request would be in the child’s best interests. But earlier in 

the dependency proceedings, Mother had been visiting L.L. 

twice per week. Mother’s petition therefore reflected a decrease 

in visitation, rather than progress in working toward the four 

visits per week permitted by Mother’s case plan. And Mother’s

enrollment in residential substance abuse treatment—which we 

reiterate was commendable—restricted her ability to visit L.L. 

in person. Moreover, Mother’s petition fails to address any of the 

remaining considerations relevant to the “best interests” inquiry,

including “the seriousness of the reason for the dependency in the 

first place” (see In re Kimberly F. (1997) 56 Cal.App.4th 519, 530) 

and the “length of time [L.L.] has been in the dependency system 

in relationship to the parental bond.” (See id. at p. 531.) These 

factors counsel against granting Mother’s petition: DCFS filed this 

case because of a serious safety issue; L.L. was only 10 months old 

when DCFS initiated the proceedings in October 2018; and since 

March 2019, L.L. has resided with paternal grandmother and 

paternal great-grandmother.

On appeal, Mother argues that, following the court’s 

denial of her petition, she made further significant progress 

in achieving sobriety and in building a strong bond with L.L. 

She points to, inter alia, her completion of residential substance 

abuse treatment and her successful unmonitored visits with L.L. 

We agree that the record reflects laudable progress by Mother. In 

general, however, we review the correctness of an order as of the 

time it was made. (See In re Josiah Z. (2005) 36 Cal.4th 664, 676 

[“an appellate court should not consider postjudgment evidence 
13

going to the merits of an appeal and introduced for the purposes 

of attacking the trial court’s judgment”]; In re Zeth S. (2003) 31 

Cal.4th 396, 405.) And although Mother argued at the section

366.26 hearing that the court should return L.L. to her custody, 

Mother did not file an updated section 388 petition describing the

additional changed circumstances. (See In re Caden C. (2021) 11 

Cal.5th 614, 630 [contrasting section 388, which permits the return 

of a child to a parent’s custody, with “the section 366.26 hearing, 

[at which] the question before the court is decidedly not whether 

the parent may resume custody of the child”].)

We therefore agree with DCFS that, should Mother wish 

to challenge the legal guardianship order on the basis of evidence

postdating her original petition, she may file a new section 388 

petition. (See In re Priscilla D. (2015) 234 Cal.App.4th 1207, 1210 

[concluding that “a legal guardianship can be terminated by a 

parent under section 388”].)

Accordingly, we conclude that the juvenile court did not abuse 

its discretion in denying Mother’s section 388 petition on the record 

then before it. 

B. The ICWA Inquiry Errors Were Harmless

Mother contends that DCFS failed to interview available 

extended family members concerning L.L.’s heritage, as required 

by California law implementing ICWA. (See § 224.2, subds. (a)

& (b); Cal. Rules of Court, rule 5.481 (a)(1) [when DCFS seeks 

a guardianship or preadoptive placement, it “must ask the child, 

if the child is old enough, and the parents, . . . extended family 

members, [and] others who have an interest in the child . . . 

whether the child is or may be an Indian child”].) Mother 

contends further that the juvenile court failed to discharge its 

duty to instruct the parties at their first appearance “to inform 
14

the court if they subsequently receive information that provides 

reason to know the child is an Indian child.” (§ 224.2, subd. (c).)

DCFS concedes, and we agree, that DCFS and the court failed 

to discharge their respective initial inquiry duties. We conclude, 

however, that no prejudice resulted from the errors.

Although California law on the issue is unsettled,7 this 

division consistently has rejected the argument that DCFS’s 

failure to inquire of extended family members mandates automatic 

reversal. (See In re S.S. (2022) 75 Cal.App.5th 575, 581 (S.S.); 

In re Darian R. (2022) 75 Cal.App.5th 502, 504 (Darian R.); In re 

A.C. (2022) 75 Cal.App.5th 1009, 1017 (A.C.).) Rather, our division 

generally has evaluated this issue to determine whether “ ‘the 

probability of obtaining meaningful information is reasonable 

in the context of ICWA.’ ” (Darian R., supra, at p. 509, quoting 

In re Benjamin M. (2021) 70 Cal.App.5th 735, 744.) In making this 

determination, we have rejected “a wooden approach to prejudice” 

(A.C., supra, at p. 1017), and refused to require further inquiry 

when, based upon the particular circumstances revealed by the 

record, it is apparent “that additional information would not have 

been meaningful to the inquiry.” (Benjamin M., supra, at p. 743; 

see, e.g., S.S., supra, at p. 582.)

Here, the record does not support that interviews of available 

extended family members would yield new information likely to 

bear on the ICWA inquiry. In addition to reflecting the parents’ 

7 “[T]here is currently a wide and varied split of authority 

among the Courts of Appeal regarding the proper standard to 

apply in determining the prejudicial effect” of ICWA error. (In 

re Y.M. (2022) 82 Cal.App.5th 901, 911 (Y.M.).) The question of 

the applicable standard presently is pending before the California 

Supreme Court. (See In re Dezi C. (2022) 79 Cal.App.5th 769, 

review granted Sept. 21, 2022, S275578.)
15

repeated denials of Indian heritage, the record discloses that both 

parents remained in close contact with biological extended family 

members. At various stages in the dependency proceedings, Mother 

lived with her own mother, and Mother maintained a relationship 

with her siblings. Similarly, Father lived with his parents and 

one sibling, and also maintained a relationship with his other 

siblings. Mother and Father “therefore presumably could have 

asked [their extended family members] at any time whether [they] 

knew of any possible Indian ancestry”—a fact that suggests that

DCFS interviews of extended family members would be unlikely 

to produce new information meaningful to the ICWA inquiry. 

(Y.M., supra, 82 Cal.App.5th at p. 917; accord, Darian R., supra, 75 

Cal.App.5th at p. 510 [initial inquiry error harmless where, among 

other factors, “[the] mother at various times lived with the relatives 

she claims DCFS failed to interview”].)

Moreover, paternal grandmother and paternal 

great-grandmother sought—and eventually obtained—legal 

guardianship of L.L. ICWA directs that “preference shall be 

given . . . to a placement with [¶] . . . [¶] . . . a member of the Indian 

child’s extended family.” (25 U.S.C. § 1915, subds. (a) & (b)(i).) 

Paternal grandmother and paternal great-grandmother thus 

“presumably would have had a strong incentive to raise any Indian 

ancestry in support of th[eir legal guardianship] goal,” yet they

did not do so. (Y.M., supra, 82 Cal.App.5th at pp. 917–918; accord,

S.S., supra, 75 Cal.App.5th at p. 582.) We therefore conclude that 

DCFS’s inquiry error did not result in prejudice.

Nor was the juvenile court’s ICWA inquiry error prejudicial. 

The court did not advise the parents during their first appearance 

of the duty to disclose any newly acquired ICWA information; 

however, the court did confirm the parents’ denials of Indian 

heritage on the record and subsequently issued a written order 
16

directing the parents to provide any updated ICWA information 

to their attorneys, the court, and DCFS. Court-appointed counsel 

represented the parents throughout the dependency proceedings,

and nothing in the record suggests any reason to doubt that the 

parents’ attorneys would have been aware of, and ensured their 

clients’ compliance with, the order. (See In re Daniel S. (2004) 115 

Cal.App.4th 903, 915 [“in the absence of any evidence in the record 

to the contrary, we assume the attorney discharged his duty and 

spoke with [his client],” citing Evid. Code, § 664].)

We therefore conclude that the ICWA inquiry errors here 

were harmless. 

C. Mother’s Challenge to the March 22, 2022 Orders—

Which Depends Entirely on Her Other Claims—

Also Fails

In seeking reversal of the juvenile court’s March 22, 2022 

orders, Mother relies exclusively on her arguments that (1) the 

court erred in summarily denying her section 388 petition, and 

(2) DCFS and the court each committed ICWA error. Because we 

conclude that neither of the aforementioned errors is reversible, we 

necessarily conclude that Mother’s challenge to the March 22 orders 

also fails.
17

DISPOSITION

The juvenile court’s January 18, 2022 and March 22, 2022

orders are affirmed.

NOT TO BE PUBLISHED.

ROTHSCHILD, P. J.

We concur:

CHANEY, J.

WEINGART, J.