IN RE L A LEDEE MINOR

Court of Appeals, State of Michigan
ORDER
IN RE L A LEDEE MINOR
Docket No. 371631
LC No. 2017-001407-NA
Michael J. Riordan
Presiding Judge
Christopher M. Murray
Allie Greenleaf Maldonado
Judges
Respondent-appellant, petitioner-appellee, and the Guardian Ad Litem are each invited to
file a supplemental brief within 21 days after issuance of this order addressing whether the term
“proceeding,” as used in 25 USC 1912(a) of the Indian Child Welfare Act (ICWA), 25 USC 1901 et seq.,
and MCL 712B.9(1) of the Michigan Indian Family Preservation Act (MIFPA), MCL 712B.1 et seq., is
limited to proceedings in the trial court, or whether the term encompasses both proceedings in the trial
court and on direct appeal, such that the respective notice provisions of the ICWA and MIFPA would be
triggered upon this Court, but not the trial court, receiving possible knowledge of a child’s federally-
recognized Indian tribe. Compare In re TM, 245 Mich App 181, 188; 628 NW2d 570 (2001) (explaining
that “notice is mandatory, regardless of how late in the proceedings a child’s possible Indian heritage is
uncovered”) (cleaned up) with In re Isaiah W, 1 Cal 5th 1, 11-13; 373 P3d 444; 203 Cal Rptr 3d 633
(2016) (explaining that the burden of ICWA notice is placed upon the “juvenile court”).
_______________________________
Presiding Judge
January 22, 2026
A true copy entered and certified by Jerome W. Zimmer Jr., Chief Clerk, on
Date

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