Termination under §§ 19b(3)(c)(i), (g), & (j); Reasonable reunification efforts; In re Rippy; Suspension of parenting time; MCL 712A.19b(4); In re Ott; The 70-day rule; MCL 712A.19b(1); The 28-day rule; MCR 3.977(I)(1); In re TC; Best interests of the children

The court held that the trial court did not err by suspending respondents-parents’ parenting time and then terminating their parental rights. Their rights were terminated based primarily on neglect. The trial court found they had not sufficiently benefited from services and that termination was in the children’s best interests. On appeal, the court rejected respondent-father’s argument that the trial court should not have terminated his parental rights because the suspension of his parenting time was based on the testimony of a social worker who had been the subject of disciplinary proceedings by the Disciplinary Subcommittee of the Board of Social Work. It noted the “limited” nature of the social worker’s “licensure was not particularly pivotal.” In addition, his “assessments and testimony were not the only pieces of evidence on which the trial court relied in suspending parenting time.” The court also rejected respondent-mother’s claim that the trial court should not have suspended parenting time and should not have found statutory grounds for termination. It noted the trial court’s “suspension of parenting time was amply supported by the evidence.” Further, while it was true that the mother “rectified some of the issues leading to adjudication,” there was also “evidence that she continued to be ineffective at proper supervision and she posed a risk to the children’s mental well-being. We do not have a firm and definite conviction that the trial court made a mistake in finding that the statutory grounds for termination had been established.” Finally, although the referee “could have been timelier in issuing her recommended order,” it was not “inconsistent with substantial justice to let the final order stand despite the violation of the 28-day rule, given the children’s extreme need for permanence.” It was also “not inconsistent with substantial justice to let the final order stand despite the violation of the 70-day rule, given that courtroom time needed to be found to allow the testimony of many witnesses and the extenuating circumstances of COVID-19 delays.” Affirmed.