A dependency court sustained Welf. & Inst. Code §300 petition allegations that baby E. was found to be sick and injured for reasons not adequately explained by the child’s parents. The court issued a disposition order removing baby E. and another child from the parents’ custody. The court denied reunification services and set a §366.26 hearing.

During the proceedings, the court ordered the county social services agency to notify the appropriate Indian tribes pursuant to the Indian Child Welfare Act (ICWA). The county did not issue the notices.