Reunification efforts; In re Rippy; Aggravated circumstances; MCL 712A.19a(2)(c)

Holding that respondent-father failed to show that, under the circumstances, the failure to provide him with reunification services was a plain error affecting his substantial rights, the court affirmed the order terminating his parental rights. His only argument on appeal was that terminating his rights was improper because the DHHS “did not make reasonable efforts to reunify him with” the child involved in this case. “‘Reasonable efforts to reunify the child and family must be made in all cases except those involving aggravated circumstances under MCL 712A.19a(2).’” The court noted that one such aggravating circumstance, MCL 712A.19a(2)(c), “exists if ‘[t]he parent has had rights to the child’s siblings involuntarily terminated and the parent has failed to rectify the conditions that led to that termination of parental rights.’” In this case, the termination hearing testimony “reflected that respondent’s parental rights to three of [the child’s] siblings were involuntarily terminated as a result of his significant substance-abuse issues.” Further, between 2015 and when these proceedings took place in 2024, “respondent’s substance-abuse issues had not been rectified. Instead, the record reflects that he was on probation for a substance-abuse related offense, that his probation was revoked because of his continued drug use, and that he was in a court-ordered treatment program to treat his substance abuse at the time of the termination hearing.”