Termination under § 19b(3)(j); Reasonable reunification efforts; MCL 712.19a(2); Principle that reunification efforts are not required where termination is the DHHS’s goal; MCR 3.977(E); In re Moss Minors; Reaching the right result for the wrong reason; Demski v Petlick; Best interests of the children; In re Mason

The court held that respondent-father was not entitled to reunification services, that termination of his parental rights was not premature, and that termination was in the child’s best interests. Respondent was charged with murder in the death of his girlfriend (the child’s mother). He later pled no contest to the existence of a statutory ground for termination of his parental rights—that the child was reasonably likely to be harmed if placed in his care. His rights were subsequently terminated. On appeal, the court rejected his argument that the DHHS failed to provide reasonable reunification services, noting that “reunification efforts are not required ‘when termination of parental rights is the agency’s goal’ from the outset.” Because the DHHS sought termination of respondent’s parental rights in the initial petition, he “was not entitled to reunification services.” It also rejected his claim that termination was premature, finding that clear and convincing evidence supported that he “killed the child’s mother in the child’s presence. A jury ultimately might determine that this evidence is insufficient to establish beyond a reasonable doubt that respondent committed murder. But that could not prevent a civil court from finding termination appropriate.” Finally, it rejected his claim that termination was not in the child’s best interests, noting that, in its ruling, the trial court explicitly discussed the child’s “placement with her maternal grandparents and concluded that [her] need for stability and the risk of harm to [the child] because of respondent’s involvement in her mother’s death outweighed the relative placement factor.” Affirmed.