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In re Jesse E.
Jason E. (father) appeals from the juvenile courts order terminating his parental rights to Jesse E. (minor). Father is a member of the Choctaw Nation of Oklahoma, and minor is eligible to be a member. According to father, the Choctaw Nation of Oklahoma participated in the dependency proceedings below and, until the very end, expressed a preference for legal guardianship or long term foster care as the minors permanent plan. However, at the end, the Choctaw Nation of Oklahoma consented to adoption as long as it was an open adoption. Father contends that this matter must be remanded for a new hearing under Welfare and Institutions Code section 366.26[1]because: (1) the Indian Child Welfare Act (ICWA) required that the Choctaw Nation of Oklahoma receive notice of a change in the law that was added by statute in 2006; i.e., the new Indian child exception to the termination of parental rights; and (2) the Choctaw Nation of Oklahoma consented to an open adoption even though there is no such thing, so its consent was void. Court find no error and affirm.

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