e-Journal Summary

e-Journal Number : 77207
Opinion Date : 03/24/2022
e-Journal Date : 04/05/2022
Court : Michigan Court of Appeals
Case Name : In re Taylor
Practice Area(s) : Termination of Parental Rights
Judge(s) : Per Curiam – O’Brien, Shapiro, and Boonstra
Full PDF Opinion
Issues:

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

Summary

Holding that § (c)(i) existed and the trial court did not err by finding that the DHHS made reasonable efforts to reunite respondent-mother with the child, the court affirmed termination of her parental rights. Respondent argued that the DHHS did not account for her sleeping disorder. While she maintained that “her sleep issues caused her to miss parenting-time visits, she did not testify that these issues affected her ability to participate and benefit from the other services offered to her.” The record demonstrated the DHHS provided relevant services to her, “but she either did not fully avail herself of the proffered services or failed to meaningfully benefit from them.” Also, as to § (c)(i), the court held that “after two years of services, respondent had failed to make meaningful progress on her mental health stability. And respondent’s alleged sleep disorder was a separate issue that had no bearing on whether the statutory grounds were met given our conclusion that reasonable reunification efforts were made.” Thus, the trial court did not clearly err by terminating her parental rights under § (c)(i).

Full PDF Opinion