In re T.N. CA2/5
Over the course of 13 months, the juvenile court assumed dependency jurisdiction over T.N., Jr. (T.N.), terminated reunification services provided to his father, T.N., Sr. (Father), and eventually terminated Father’s parental rights over T.N. The Department of Children and Family Services (the Department) concedes it inadequately investigated whether T.N. was an Indian child within the meaning of state and federal law. We accept the concession and are thus left with only one issue to resolve: whether the manner in which the juvenile court sent notice to Father of his appellate rights, which did not strictly comply with a statute and rule requiring notice to be sent to his “last known address,” means he can now challenge the court’s decision to terminate his reunification services—a challenge that would otherwise be barred by his failure to earlier seek appellate court review of that decision.
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