Filed 8/20/26 In re C.S. CA4/2
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for
publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication
or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
FOURTH APPELLATE DISTRICT
DIVISION TWO
In re C.S., a Person Coming Under the
Juvenile Court Law.
RIVERSIDE COUNTY DEPARTMENT
OF PUBLIC SOCIAL SERVICES, E088065
Plaintiff and Respondent, (Super.Ct.No. DPRI2300455)
v. OPINION
J.S.,
Defendant and Appellant.
APPEAL from the Superior Court of Riverside County. Malvina K. Ovanezova,
Commissioner. Affirmed.
Timothy O’Crowley, under appointment by the Court of Appeal, for Defendant
and Appellant.
Minh C. Tran, County Counsel, Jamila T. Purnell, Assistant County Counsel, and
Julie Jarvi, Deputy County Counsel for Plaintiff and Respondent.
1
A mother appeals from the termination of her parental rights over her son. She
argues (1) the county welfare department failed to conduct an adequate inquiry under the
Indian Child Welfare Act of 1978 (ICWA), (2) the juvenile court failed to determine the
applicability of Welfare and Institutions Code section 306.6, which permits courts to
allow a tribe that is not federally recognized to participate in dependency proceedings,
and (3) the juvenile court lacked the power to amend its original termination order to add
1
an alternative name for the child’s father. We reject all three arguments and affirm.
I. FACTS
Defendant and appellant J.S. (mother) tested positive for amphetamine and
fentanyl when she was admitted to the hospital for an emergency cesarean section in
December 2023. Her child C.S. tested positive for fentanyl at birth. Mother admitted to
relapsing during her pregnancy but said that she wanted to enter a residential drug
treatment program after discharge from the hospital, so she could get clean for the child.
The child’s father, defendant R.Q. (father), also had a history of substance abuse. Mother
said she had lived with father and his parents (paternal grandparents) on and off, but she
and father were “just talking and dating when she got pregnant.” The status of their
relationship was “unknown,” though she expressed wanting to coparent with him because
he had been supportive and present.
1
Undesignated statutory references are to the Welfare and Institutions Code. “In
addition, because ICWA uses the term ‘Indian,’ we do the same for consistency, even
though we recognize that other terms, such as ‘Native American’ or ‘indigenous’ are
preferred by many.” (In re Benjamin M. (2021) 70 Cal.App.5th 735, 739, fn. 1,
disapproved on another ground by In re Dezi C. (2024) 16 Cal.5th 1112, 1152, fn. 18.)
2
Plaintiff and respondent Riverside County Department of Public Social Services
(department) filed a dependency petition for the child but did not request that he be
removed from parental care. Mother went to a residential treatment program after her
discharge from the hospital, and the child was able to live with her there after his release
from the hospital about a week later.
At the initial hearing on the dependency petition in January 2024, father was found
to be the presumed father of the child. The court found the department had made a prima
facie showing and followed the department’s recommendation that the child remain in
parental custody. In February 2024, the court sustained the dependency petition, finding
the child came within section 300, subdivision (b)(1). The court again ordered the child
to remain in parental care, and ordered family maintenance services for the parents.
The department filed a supplemental dependency petition in August 2024, alleging
that mother had relapsed, testing “positive for methamphetamine at a high concentration
level” on June 25, 2024, and again on July 1, 2024, and that father knew or reasonably
should have known about mother’s abuse of controlled substances and failed to intervene.
The juvenile court detained the child from parental care at the initial hearing on the
supplemental petition. In September 2024 the parents signed a written waiver of rights,
and the juvenile court sustained the supplemental petition, removed the child from
parental custody, and ordered reunification services for both parents.
Reunification services were unsuccessful. Neither parent was able to maintain
sobriety and both acquired new criminal charges. In May 2025, the juvenile court
3
terminated reunification services and set a section 366.26 hearing. On March 4, 2026, the
juvenile court found it was likely C.S. would be adopted and ordered parental rights
terminated. There was no discussion of ICWA at this hearing, and the court made no
express ICWA findings. However, the signed Judicial Council form JV-320
memorializing the court’s order was filed the next day, and that form included findings
that the court and department had fulfilled their duty of inquiry and that ICWA did not
apply.
On March 15, 2026, the department submitted an ex parte application requesting
the original JV-320 order be amended to include father’s name as stated on the child’s
birth certificate as an alternative name (“an AKA”) for him to facilitate the adoption
2
process. The juvenile court signed the amended order on March 17, 2026. Both the ex
parte application and the signed amended order were file-stamped on March 18, 2026.
Meanwhile, on March 17, 2026, mother filed a notice of appeal from the original
termination order. Mother did not file a notice of appeal as to the amended order.
II. DISCUSSION
A. ICWA
Mother argues that the department’s initial ICWA inquiry was inadequate because
it did not do more to attempt to contact two paternal relatives, an unnamed aunt of the
paternal grandmother and paternal grandfather’s aunt, identified by her first name Karen
2
On the original order, father’s name included his full first and last names, plus
his middle initial and the Roman numeral suffix “III.” On the child’s birth certificate, the
father’s name included his full first, middle, and last names, with no suffix.
4
and the information that she lives in Whittier. Citing section 224.2, mother also argues
the department failed to “contact the Bureau of Indian Affairs or the State Department of
Social Services for assistance as required by statute.” We are not persuaded.
1. Additional facts
During the dependency, many of the child’s relatives were asked about possible
Native American ancestry. Initially, mother and father both denied that they had any
Native American ancestry or affiliation, and father continued to do so throughout the
dependency. In January 2024, however, mother indicated on her Parental Notification of
Indian Status form that she may be a member of or eligible for membership in the
Juaneño Band of Mission Indians. In August 2024, a maternal great aunt told the social
worker “we are San Juan Capistrano Indian, a part of the Ojan Tribe Mission Indian, also
known as Juaneño Band Mission Indian.” In September 2024, the department confirmed
3
that “the Juaneño tribe is not federally recognized.”
In August 2024, paternal grandmother responded to a social worker’s ICWA
inquiry: “I don’t think so, but my aunt stated we have a little Native American Ancestry.”
In September 2024, the juvenile court asked paternal grandmother if she had Native
American ancestry, and she responded “As far as I know, no. I heard we kind of do, but
I’m not sure.” She had not heard mention of any specific nation or tribe, and said she
would have to talk to her paternal aunt to get more information because “[s]he’s the one
3
Mother’s counsel had conceded in January 2024 that “the Junaneño Band of
Mission Indians” is “not federally recognized.”
5
that said we might have a little bit, so I don’t know.” When the department followed up
with paternal grandmother, however, she said she did not know her aunt’s contact
information. She told the social worker she would call her other paternal aunt instead.
Paternal grandfather also said that his family may have Native American ancestry
but did not have any information as to any specific tribe. He identified two older
relatives who may have had information, but both were deceased. He also said his
“uncle’s daughter’s son” has Native American ancestry, but that person’s father, who is
“deceased and not related to their family,” was the one who had Native American
ancestry. He said a half-sister of that person’s father has Native American ancestry, but
he did not know her name or any other contact information. Paternal grandfather also
said he had “an aunt named Karen who lives in Whittier that might have knowledge on
Native American ancestry,” but he had no way to contact her.
The department also asked several other paternal relatives about ICWA matters. A
paternal great-aunt and paternal cousin both denied any Native American ancestry, and a
paternal aunt said she did not know.
2. Applicable Law
The federal Indian Child Welfare Act establishes minimum standards “for the
removal of Indian children from their families and the placement of such children in
foster or adoptive homes which will reflect the unique values of Indian culture.” (25
U.S.C. § 1902.) Cal-ICWA, California’s counterpart to ICWA, imposes on juvenile
courts and county welfare departments “an affirmative and continuing duty to inquire”
6
whether a child subject to a section 300 petition may be an Indian child. (§ 224.2, subd.
(a); see In re D.F. (2020) 55 Cal.App.5th 558, 566.) “This continuing duty can be divided
into three phases: the initial duty to inquire, the duty of further inquiry, and the duty to
provide formal ICWA notice.” (Ibid.)
The initial duty applies in every dependency. (In re J.S. (2021) 62 Cal.App.5th
678, 686; see § 224.2, subd. (b).) The initial duty expands under section 224.2,
subdivision (b), when a child is removed from their home. Under that provision, if a
child is “received and maintained in temporary custody of a county welfare department
pursuant to . . . Section 306, or if they were initially taken into protective custody
pursuant to a warrant described in Section 340,” the department’s obligation includes
4
asking the “extended family members” about the child’s Indian status. (§§ 224.2, subd.
(b)(2), 224.1, subd. (c)(1).) California Rules of Court, rule 5.481 implements section
224.2, subdivision (b), by requiring inquiry of extended family in every case in which the
department seeks to place the child. (Cal. Rules of Court, rule 5.481(a)(1).)
Nevertheless, reversal is not required “in all cases in which every possible extended
family member has not been asked about the child’s Indian ancestry.” (In re Dezi C.
(2024) 16 Cal.5th 1112, 1140 (Dezi C.).) Instead, ICWA requires the department to ask
for information from individuals who are reasonably available. (Ibid.; see also id. at p.
4
“‘Extended family member’ has the same meaning as defined by the law or
custom of the Indian child’s tribe or, in the absence of such law or custom, shall be a
person who has reached 18 years of age and who is the Indian child’s grandparent, aunt
or uncle, brother or sister, brother-in-law or sister-in-law, niece or nephew, first or second
cousin, or stepparent.” (§ 224.1, subd. (c)(1); see also 25 U.S.C. § 1903(2) [same].)
7
1143 [“‘the obligation is only one of inquiry and not an absolute duty to ascertain or
refute Native American ancestry’”].)
When the initial inquiry gives the juvenile court or social worker “reason to
believe that an Indian child is involved” (§ 224.2, subd. (e)), the court and social worker
must conduct further inquiry to “determine whether there is reason to know a child is an
Indian child.” (§ 224.2, subd. (e)(2).) There is reason to believe an Indian child is
involved if the court or the social worker “has information suggesting that either the
parent of the child or the child is a member or citizen, or may be eligible for membership
or citizenship, in an Indian tribe.” (§ 224.2, subd. (e)(1).) Further inquiry includes,
among other things, interviewing the parents and extended family members to gather the
information required for the ICWA notice. (§§ 224.2, subd. (e)(2)(A), 224.3, subd.
(a)(5).)
“[E]rror resulting in an inadequate initial Cal-ICWA inquiry requires conditional
reversal with directions for the child welfare agency to comply with the inquiry
requirement of section 224.2, document its inquiry in compliance with [California Rules
of Court,] rule 5.481(a)(5), and when necessary, comply with the notice provision of
section 224.3. When a Cal-ICWA inquiry is inadequate, it is impossible to ascertain
whether the agency’s error is prejudicial.” (Dezi C., supra, 16 Cal.5th at p. 1136.)
Although Dezi C. did “not have occasion to decide what constitutes an adequate and
proper inquiry necessary to satisfy section 224.2,” our Supreme Court noted there that
“the juvenile court’s fact-specific determination that an inquiry is adequate, proper, and
8
duly diligent is ‘a quintessentially discretionary function’ [citation] subject to a
deferential standard of review.” (Id. at p. 1141.) “‘“On a well-developed record, the
court has relatively broad discretion to determine whether the agency’s inquiry was
proper, adequate, and duly diligent on the specific facts of the case. However, the less
developed the record, the more limited that discretion necessarily becomes.”’” (Ibid.)
Here, we are not reviewing a juvenile court’s resolution of an evidentiary conflict,
but the juvenile court’s implied finding that the department’s “inquiry and due diligence
were ‘proper and adequate.’” (Dezi C., supra, 16 Cal.5th at p. 1134.) We thus are “not
concerned with the outcome” as to the likelihood of whether the child is an Indian child.
(Id. at p. 1144.) We do not limit our review to “[e]nforcing the requirement of an
adequate inquiry only in cases in which the record affirmatively demonstrates a reason to
believe the child is an Indian child.” (Id. at p. 1147.) Instead, we must “ensur[e] that
tribal heritage is acknowledged and inquired about in dependency cases.” (Id. at p.
1148.) This requires us to engage in a searching review to protect the tribal interests,
which Dezi C. emphasized are compelling and legally protected. (Ibid.) Yet the
deferential standard means an inquiry need not be perfect to be adequate.
3. Analysis
We find no error in the juvenile court’s determination that the department’s initial
inquiry was adequate. Neither paternal grandmother’s unnamed aunt nor paternal
grandfather’s aunt Karen from Whittier were reasonably available for inquiry. Although
paternal grandmother initially said she would provide her aunt’s contact information, she
9
later said she could not do so. The paternal grandfather said he had no way to contact his
aunt Karen. Moreover, unlike an aunt, “[a] great-aunt is not an ‘extended family
member’ for purposes of the mandatory initial inquiry requirements of ICWA.” (In re
J.F. (2025) 109 Cal.App.5th 468, 471; see § 224.1, subd. (c)(1).) The two relatives at
issue here are yet another generation older than a child’s great-aunt. They are distant
relations, not “extended family members” as that term is used in ICWA and Cal-ICWA.
We also find no error in the department’s failure to contact the Bureau of Indian
Affairs (BIA) or the State Department of Social Services. The purpose of contacting
these agencies as part of a further inquiry is “for assistance in identifying the names and
contact information of the tribes in which the child may be a member or citizen, or
eligible for membership or citizenship in.” (§ 224.2, subd. (e)(2)(B).) Here, neither
father nor any other paternal relative provided sufficient information about possible tribal
affiliation to identify specific tribes in which the child might be a member, so the
department did not need assistance in identifying the names and contact information of
any tribes. (See In re H.M. (2025) 109 Cal.App.5th 1171, 1184 [department’s duty of
further inquiry did not require contacting the BIA because it did not need assistance
identifying name or contact information for the tribes].) The child’s maternal family
identified a specific tribe, but there was no dispute that it is not a federally recognized
tribe. “The requirements of the ICWA apply only to federally recognized tribes.” (In re
A.C. (2007) 155 Cal.App.4th 282, 286; see 25 U.S.C. § 1903(8).)
10
B. Section 306.6
Mother argues the juvenile court erred by failing to determine whether section
5
306.6 applied. We find no error.
“Section 306.6 permits the court in a dependency action to allow a tribe which is
not federally recognized to appear in the proceeding and present information to the
court.” (In re A.C., supra, 155 Cal.App.4th at p. 286.) Under the statute, a tribe “may”
participate in a juvenile dependency proceeding “upon request of the tribe.” (§ 306.6,
subd. (a).) The tribe may “upon consent of the court: [¶] (1) Be present at the hearing . . .
[¶] (2) Address the court. [¶] (3) Request and receive notice of hearings. [¶] (4) Request
to examine court documents relating to the proceeding. [¶] (5) Present information to the
court that is relevant to the proceeding. [¶] (6) Submit written reports and
recommendations to the court. [¶] (7) Perform other duties and responsibilities as
requested or approved by the court.” (Id., subd. (b)(1)-(7).) The statute says the court
“shall, on a case-by-case basis, make a determination if this section is applicable and may
request information from the tribe, or the entity claiming to be a tribe, from which the
child is descended for the purposes of making this determination, if the child would
otherwise be an Indian child pursuant to subdivision (a).” (Id., subd. (e); see also id.,
subd. (a) [section 306.6 applies in “a dependency proceeding involving a child who
5
The department argues mother forfeited the argument by failing to raise it in the
juvenile court. Applying the general preference for deciding cases on their merits where
possible, we exercise our discretion to decide mother’s argument on the merits, without
deciding whether the argument could be deemed forfeited.
11
would otherwise be an Indian child, based on the definition contained in [ICWA], but is
not an Indian child based on the child’s Indian tribe not having federal recognition”].)
Tribal participation under section 306.6 is thus discretionary. Section 306.6,
subdivision (d), explains that the statute “is intended to assist the court in making
decisions that are in the best interest of the child by permitting a tribe in the
circumstances set out in subdivision (a) to inform the court and parties to the proceeding
about placement options for the child within the child’s extended family or the tribal
community, services and programs available to the child and the child’s parents as
Indians, and other unique interests the child or the child’s parents may have as Indians.”
“By its terms, the statute does not require that any notice be sent to a
nonrecognized tribe. (§ 306.6.) Further, the statute specifically does not apply either
notice provisions found in the ICWA or provisions in state law implementing notice
provisions of the ICWA to this situation. (§ 306.6, subd. (d).)” (In re A.C., supra, 155
Cal.App.4th at pp. 286-287.)
Mother’s argument is unpersuasive for several reasons. First, we reject its premise
that the juvenile court in fact failed to decide whether section 306.6 applies. The record
shows it did not make any express determination under section 306.6, subdivision (e).
On appeal, however, the general rule is that, “[a]bsent evidence to the contrary, we
presume that the trial court knew the law and followed it.” (People v. Ramirez (2021) 10
Cal.5th 983, 1042.) Applying this presumption, the record here is compatible with either
an implicit finding that section 306.6 does not apply or an implicit exercise of discretion
12
not to request information from the tribe. The juvenile court learned of the asserted
connection to the Juaneño Band of Mission Indians from mother’s Parental Notification
of Indian Status form and the Department’s reports, but did not act on it.
Second, the evidence does not require the conclusion that the child “would
otherwise be an Indian child” if his tribe were federally recognized. (§ 306.6, subds. (a),
(e).) ICWA defines “‘Indian child’” as “any unmarried person who is under age eighteen
and is either (a) a member of an Indian tribe or (b) is eligible for membership in an Indian
tribe and is the biological child of a member of an Indian tribe.” (25 U.S.C. § 1903(4).)
There is evidence that the child may have some connection to a tribe that is not federally
recognized. Mother’s own claim of Native American ancestry, however, was ambiguous,
checking a box to indicate that she “[is] or may be a member of, or may be eligible for
membership in” the “Juaneño Band of Mission Indians.” And she did not check the box
indicating that the child is, or may be, a member of, or eligible for membership in that
tribe. Mother never affirmatively established that either she or the child is a member of
that tribe.
And finally, even assuming mother and/or the child are tribal members, neither the
department nor the juvenile court was obligated to give notice to the tribe of the
proceedings. (In re A.C., supra, 155 Cal.App.4th at pp. 286-287.) Nothing prevented
mother from notifying the tribe of the proceedings and inviting it to request to participate
in the proceedings. There is no evidence the tribe ever made such a request, however, so
13
we have no cause to consider whether the juvenile court would have abused its discretion
by denying it.
C. Amended termination order
Mother argues the juvenile court “was without power to amend the termination of
parental rights order after Mother filed the notice of appeal.” This argument, as phrased,
muddles together two separate issues: (1) the jurisdiction of a juvenile court to amend a
judgment or appealable order after the filing of a notice of appeal, and (2) the statutory
prohibition against collateral attacks on orders terminating parental rights codified in
6
section 366.26, subdivision (i)(1). Nevertheless, the argument raises several potential
questions, including (1) whether mother’s March 17, 2026 notice of appeal from the
original, March 4, 2026 termination order was filed before or after the amended
termination order, which was signed by the court March 17, 2026, even though it was not
file-stamped until a day later, (2) whether the juvenile court had the power to amend the
March 4, 2026 order after it was issued, given section 366.26, subdivision (i)(1)’s
language that “[a]fter making the order, the juvenile court shall have no power to set
aside, change, or modify it,” and (3) the interplay between that statutory language and a
court’s “inherent power to correct clerical errors in its records so as to make these records
6
“An order of the court permanently terminating parental rights under this section
shall be conclusive and binding upon the child, upon the parent or parents and, upon all
other persons who have been served with citation by publication or otherwise as provided
in this chapter. After making the order, the juvenile court shall have no power to set
aside, change, or modify it, [with an exception not relevant here], but nothing in this
section shall be construed to limit the right to appeal the order.” (§ 366.26, subd. (i)(1)
(italics added).)
14
reflect the true facts,” which “exists independently of statute” and is “unaffected by the
pendency of an appeal or a habeas corpus proceeding.” (In re Candelario (1970) 3
Cal.3d 702, 705; see In re Z.H. (2024) 107 Cal.App.5th 1014, 1025-1026 [distinguishing
clerical error from judicial error which cannot be corrected by amendment].)
Before considering any of these questions, however, we must consider the scope of
our own jurisdiction. (See California Redevelopment Assn. v. Matosantos (2011) 53
Cal.4th 231, 252 [“we have an independent obligation in this as in every matter to
confirm whether jurisdiction exists”].) The department argues we lack jurisdiction
because mother did not file a notice of appeal from the amended termination order.
“A judgment in a proceeding under Section 300 may be appealed in the same
manner as any final judgment, and any subsequent order may be appealed as an order
after judgment.” (§ 395, subd. (a)(1).) “The dispositional order is the ‘judgment’ . . . and
all subsequent orders are appealable.” (In re S.B. (2009) 46 Cal.4th 529, 532.) Thus, the
amended termination order is an appealable postjudgment order.
An appeal from a juvenile court order generally must be filed within 60 days of
the order. (Cal. Rules of Court, rule 8.406(a).) “This is a jurisdictional deadline,
meaning that courts lack the power to extend it, regardless of whether failure to meet the
deadline was ‘wilful [sic] or inadvertent,’ ‘reasonable or unreasonable,’ or rooted in
‘good faith or not.’” (In re A.R. (2021) 11 Cal.5th 234, 246.) Nevertheless, while the
“timely filing of a notice of appeal is an absolute jurisdictional prerequisite . . . technical
accuracy in the contents of the notice is not.” (K.J. v. Los Angeles Unified Sch. Dist.
15
(2020) 8 Cal.5th 875, 882-883.) “Once a notice of appeal is timely filed, the liberal
construction requirement compels a reviewing court to evaluate whether the notice,
despite any technical defect, nonetheless served its basic function—to provide notice of
who is seeking review of what order or judgment—so as to properly invoke appellate
jurisdiction.” (Id. at p. 883.)
A “notice of appeal must be liberally construed.” (Cal. Rules of Court, rule
8.100(a)(2).) That is, the appeal must be “‘liberally construed . . . to protect the right of
appeal if it is reasonably clear what [the] appellant was trying to appeal from, and where
the respondent could not possibly have been misled or prejudiced.’” (In re Joshua S.
(2007) 41 Cal.4th 261, 272.) The liberal construction rule exists to “‘implement the
strong public policy favoring the hearing of appeals on the merits.’” (K.J., supra, 8
Cal.5th at p. 882.)
To be sure, a notice of appeal must “identif[y] the particular judgment or order
being appealed.” (Cal. Rules of Court, rule 8.405(a)(3).) Under the liberal construction
rule, though, once a notice of appeal is timely filed from one appealable order, a court can
construe it as encompassing a separate, related appealable order as to which it is timely
filed, if doing so aligns with the filer’s intent and there is no unfair prejudice to the
respondent. For example, in a recent opinion, our Supreme Court construed a notice of
appeal filed by an appellant to include a sanctioned attorney who was not listed as an
appellant in the notice. (K.J., supra, 8 Cal.5th at p. 878.) In doing so, the court stated
that this was a less common type of liberal construction and stated that “the rule of liberal
16
construction is most commonly employed to remedy defects in a notice’s designation of
the order or judgment that is being appealed from.” (Id. at p. 885.) An example of this
more common employment of liberal construction is In re Jordan (1992) 4 Cal.4th 116,
131, fn. 9, where our Supreme Court construed a notice of appeal listing only one of the
petitioner’s two convictions as an appeal from both, where judgment and sentencing had
been “rendered simultaneously in both cases.”
In this case, mother filed a notice of appeal from the original order terminating her
parental rights. There is a technical defect in the notice’s designation of the order being
appealed from, in that it does not also specify an appeal from the amended termination
order. Nevertheless, mother’s intent to challenge the termination of her parental rights—
whether in the original order or any amended order—is manifest. The notice of appeal
was either timely filed or slightly premature as to the amended termination order. Either
way, we discern no prejudice to the department from construing the notice of appeal to
constitute notice as to both orders, which differ only by the insertion of an additional
name for father. Thus, we find it appropriate, in the interests of justice, to permit
mother’s appeal to be heard on the merits as to both the original and amended termination
orders.
As to the merits of mother’s arguments about the amended termination order,
however, we are not persuaded. The purpose of section 366.26, subdivision (i)(1) is to
“prohibit[] virtually all collateral attacks on orders terminating parental rights,” thereby
protecting both the state’s and the child’s “exceptionally strong interests in making sure
17
the matter is determined conclusively.” (In re J.W. (2020) 53 Cal.App.5th 347, 360-361.)
The modification at issue here did not alter the substance of the original termination
order, only adding father’s name as stated on the child’s birth certificate to allow the
adoption process to proceed. This is not a collateral attack on the termination order, but
rather correction of a clerical error to facilitate its purpose and without amendment to its
substance. We find such an amendment well within the scope of the juvenile court’s
authority, no matter whether the amendment was filed before or after mother’s notice of
appeal, and notwithstanding section 366.26, subdivision (i)(1).
III. DISPOSITION
We affirm the orders terminating mother’s parental rights.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
RAPHAEL
_____________________________________________________________________________________________________________________________ _________________________________________
J.
We concur:
MILLER
_____________________________________________________________________________________________________________________________ _________________________________________
Acting P. J.
MENETREZ
_____________________________________________________________________________________________________________________________ _________________________________________
J.
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