Termination under §§ 19b(3)(c)(i) & (c)(ii); Children’s best interests; In re Sanborn; Whether the trial court relied on inadmissible evidence; Consideration of the children’s trauma assessments; MCR 3.977(H)(2); Reasonable reunification efforts; In re Frey; Ineffective assistance of counsel; People v Sabin (On Second Remand); Failure to object & to obtain an expert; Post-traumatic stress disorder (PTSD)

The court held that terminating respondent-mother’s parental rights was proper under §§ (c)(i) and (c)(ii), and that doing so was in her children’s best interests. As to respondent-father, it held that there was no error in the trial court’s consideration of “the children’s trauma assessments during the termination hearing” and that termination under § (c)(i) was proper. Further, the court found that reasonable efforts were made to reunify him with the children and it rejected his ineffective assistance of counsel claims. Thus, the court affirmed the order terminating both respondents’ parental rights. As to the mother, it concluded that §§ (c)(i) and (c)(ii) were established by clear and convincing evidence in light of her “failure to end her relationship with father and acknowledge the trauma that her children experienced while living with her, combined with her failure to obtain appropriate housing, employment, and parenting skills to care for six children[.]” She contended she should have been allowed “more time to participate in intensive services for domestic violence.” But the court noted she participated in such services and that she failed to show “she would participate in any further domestic-violence services in any meaningful way or that more time would have made a difference.” The court also determined that the trial court did not clearly err in finding termination was in the children’s best interests. Testimony showed they “were doing well in their placement with their maternal grandparents who agreed to adopt them. Although both parents participated in services, neither parent rectified the issues that caused the children’s removal—lack of appropriate housing and domestic violence.” As to the father, termination hearing testimony established that he “had inconsistent employment throughout the case and that he failed to provide any proof of income. He also failed to obtain appropriate housing as he lived with friends and there was no room for the children.” Four of the children were diagnosed with PTSD, and he declined to accept that they were afraid of him. While he “participated in services for anger management and domestic violence,” he still exhibited anger issues. As to reasonable reunification efforts, he “was offered multiple services and failed to show benefit from” them.