Termination under § 19b(3)(b)(i); Physical harm; In re LaFrance; Reasonable reunification efforts; MCL 712A.18f(3)(b) & (c); In re Hicks/Brown; In re Mason; A parent’s responsibility to participate in & benefit from the services offered; In re Frey; Order of jurisdiction; MCR 3.205(A); In re AP; Child’s best interests; MCL 712A.19b(5); Parent-child bond; Friend of the Court (FOC)

Holding that reasonable reunification efforts were made, § (b)(i) was met, and termination was in the child’s best interests, the court affirmed termination of respondent-father’s parental rights. His rights were terminated on the basis of his lack of parenting skills, anger issues, history of domestic violence, emotional instability, and substance abuse problems. On appeal, the court rejected his argument that the DHHS failed to make reasonable reunification efforts because it did not provide him with parenting time due to an FOC order and did not help him address his barriers to reunification. His contention that “the DHHS’s reliance on the FOC order prevented him from having contact with” the child overlooked “his own actions and refusal to participate in services and” lacked merit. In addition, he “was offered services that he could have completed in conjunction with his work schedule.” The court also rejected his claim that there were no statutory grounds to support termination, finding § (b)(i) was met. Sufficient evidence established a reasonable likelihood that the child “would suffer injury in the foreseeable future if he were in respondent’s care[.]” Finally, the court rejected his claim that termination was not in the child’s best interests because they had a strong bond. Given his “substance abuse, lack of parenting skills, history of domestic violence, emotional instability,” the child’s time in foster care, need for permanence and stability, bond with another child, and respondent’s lack of contact with the child throughout the proceedings, the trial court did not err by finding termination was in the child’s best interests.