Termination under §§ 19b(3)(b)(i), (i), & (k)(iii); Reasonable reunification efforts; MCL 712A.19a(2)(c); In re Smith; Principle that evidence of how a parent treats one child is evidence of how he or she may treat another; In re Hudson; Child’s best interests; In re Moss Minors; In re Olive/Metts Minors; In re White

Holding that §§ (b)(i), (i), and (k)(iii) supported termination, and that it was in the child’s (K) best interests, the court affirmed the order terminating respondent-father’s parental rights. He argued that termination under § (i) was improper because he was not provided a case service plan or services after K’s removal. But reasonable reunification efforts “need not be made if ‘the parent has had rights to the child’s siblings involuntarily terminated and the parent has failed to rectify the conditions that led to that termination of parental rights.’” Given that respondent’s parental rights to two other children were previously terminated, he had “made no effort to rectify the conditions that led to that termination,” and the DHHS was not obligated to provide him “with services, the trial court did not clearly err by terminating respondent’s parental rights” to K under § (i). The court also held that clear and convincing evidence supported termination under §§ (b)(i) and (k)(iii) because he committed “severe child abuse” against one of K’s siblings, who suffered second- and third-degree burns. As to K’s best interests, the trial court’s analysis focused on respondent’s ability to provide K “with safety, stability, and permanence.” Regardless of whether the cause of the other child’s “injuries was deliberate abuse or negligence on respondent’s part, the record” supported its determination that K “would be at substantial risk of physical injury if returned to respondent’s care.”