e-Journal Summary

e-Journal Number : 75253
Opinion Date : 04/15/2021
e-Journal Date : 04/22/2021
Court : Michigan Court of Appeals
Case Name : In re Budziak
Practice Area(s) : Termination of Parental Rights
Judge(s) : Per Curiam – Cameron, K.F. Kelly, and M.J. Kelly
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Issues:

Termination under § 19b(3)(c)(i); Reasonable reunification efforts

Summary

The court held that plain error did not occur when the trial court concluded that the DHHS made reasonable efforts to reunify respondent-mother with her children. Also, § (c)(i) existed to terminate her parental rights. She asserted that the DHHS failed to provide tailored services to address her mental health, lack of transportation, lack of access to a telephone or computer, medical concerns, and domestic violence concerns. Although the DHHS “created a service plan that was meant to facilitate the children’s return to respondent’s home, respondent failed to fulfill her commensurate responsibility to participate in the services that were offered.” The DHHS made reasonable efforts to provide mental health services. The record reflected that “respondent was referred to mental health professionals, engaged in mental health services for a period of time, and was prescribed medication. However, respondent failed to participate in the services on a regular basis and lost access to her medication as a result.” Further, the DHHS made reasonable efforts to provide housing and employment services. Also, it made reasonable efforts to foster respondent’s parenting skills. In sum, she was “offered services meant to address her mental health needs, inadequate housing, and inadequate parenting ability, but respondent failed to fulfill her commensurate responsibility to participate in the services that were offered to her.” Affirmed.

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