Termination of parental rights; Child’s best interests; MCL 712A.19b(5); In re LaFrance; Reasonable reunification efforts; In re Sanborn; Aggravating circumstances; MCL 712A.19a(2); In re Rippy; Effect of abuse; MCL 722.638(1)(a); In re Mason; Accommodations; In re Hicks/Brown

The court held that termination of respondent-father’s parental rights was in the child’s (LK) best interests, and the trial court was not required to provide him with reunification efforts or accommodations. His rights were terminated on the basis of his history of serious physical and verbal abuse of his children and their mother. On appeal, the court rejected his argument that termination was not in LK’s best interests, noting the trial court did not err by finding his “home was a dangerous, unsafe, and unstable environment for LK due to [his] verbally and physically abusive behavior.” The trial court found he “had shown no ability to parent LK and that [his mother] could provide [him] with the permanency, stability, and finality that he needed.” It also found “it was in LK’s best interests that he remain in the care of” his mother. The court also rejected his claim that the trial court erred by failing to provide him with a treatment plan to assist him with his mental health issues and parenting skills, and that his mental illness required reasonable accommodations tailored to his disability. It noted reasonable reunification efforts were not required because aggravating circumstances existed – abuse. As to accommodations, “reasonable efforts were not required in the first instance.” And he “cannot prevail on a claim that the DHHS failed to make reasonable accommodations for services it was not obligated to provide.” Affirmed.