Reasonable reunification efforts; MCL 712A.18f(3)(b) & (c); In re Hicks; A parent’s duty to participate in & benefit from the offered services; In re Atchley

The court held that the trial court did not err by finding the DHHS made reasonable efforts to reunify respondent-father with his children, and thus, did not err by terminating his parental rights. His rights were terminated based on substance abuse, lack of parenting skills, lack of emotional stability, and incarceration. On appeal, the court rejected his argument that the DHHS failed to make reasonable reunification efforts. It noted that although the DHHS offered him “numerous services, at the time of termination he had made no progress toward eliminating the barriers to reunification and had created a new barrier by becoming incarcerated as a result of possession of meth[].” It also rejected his claim that the DHHS did not advise him of the option of participating in Family Drug Treatment Court. He failed to “explain whether he qualified for that program or whether the services offered would have differed from those offered by” the DHHS. As to his contention that his caseworkers changed frequently during the time the children were in care, the court noted there was no indication in the record “that the frequent changes prevented” the DHHS from providing services to him or prevented him from participating in the services. In sum, respondent raised “no valid challenge to the reasonableness of the efforts of the agency.” The DHHS offered him “numerous services aimed at removing the barriers to his reunification with his children, but [he] declined to participate in the offered services.” Affirmed.