Termination under § 19b(3)(b)(i); Termination at the initial disposition; Exceptions to the reasonable reunification efforts requirement; MCL 712A.19a(2); MCL 722.638(1); Whether the trial court must specifically identify the relevant exception; Children’s best interests; Motion for reconsideration or a new trial based on the claim of effective assistance of counsel

Holding that respondent-father did not establish any grounds for relief, the court affirmed the trial court’s orders terminating his parental rights to three of his children. Respondent argued that the trial court erred in ordering termination “at the initial disposition without making the required finding of aggravated circumstances.” However, the court noted that there are exceptions to the reasonable reunification efforts requirement, and it concluded the trial court made findings establishing “beyond reasonable dispute that it determined that the exception” in MCL 712A.19a(2)(a) applied. The court determined that its “statements and findings were sufficient to establish that respondent engaged in conduct that fell within the conduct described under MCL 722.638(1), and that the children were either the child subjected to the abuse, or siblings of a child subjected to the abuse.” Thus, he did not show that the trial court plainly erred when it applied the law and determined that the DHHS could properly seek termination at the initial disposition. In addition, respondent did not identify any errors with the trial court’s findings or determination that the DHHS established grounds to terminate his parental rights under § (i). Thus, the court did not need to “address whether the trial court erred in any respect when it terminated” his rights on that basis. He did not show that the trial court clearly erred when it determined that the DHHS “had established at least one statutory ground for terminating his parental rights to each of the children.” Also, he failed to show that it “clearly erred when it found that termination was in the best interests of” all the children. Finally, he did not show that the trial court’s decision to deny his motion for reconsideration or a new trial based on ineffective assistance of counsel fell outside the range of principled outcomes.