Reasonable reunification efforts; Effect of aggravated circumstances; MCL 712A.19a(2)(a); MCL 722.638; In re Sanborn; Termination under § 19b(3)(b)(ii); Children’s best-interests; MCL 712A.19b(5); In re Moss Minors

Holding that the trial court did not err in finding that reasonable reunification efforts were made, that clear and convincing evidence supported termination under § (b)(ii), and that it was in the children’s best interests, the court affirmed termination of respondent-father’s parental rights. After the children disclosed repeated sexual abuse by the paternal grandfather to the father, he allegedly disbelieved them. The children were placed with their maternal aunt and uncle. At adjudication, the father pled no contest to petition allegations. At disposition, the foster-care specialists testified he continued to reside with the grandfather, refused one of the children’s medication authorization, provided no support, blocked a home inspection, and did not engage in services. The court found “there was likely sufficient evidence in the record to conclude that reasonable efforts were not necessary because of the aggravated circumstances.” But the trial court did not make this finding on the record. In any event, reasonable-efforts attempts were thwarted by the father’s noncommunication. As to statutory grounds, he had the opportunity to prevent abuse but failed to act, and there was a reasonable likelihood of harm if returned, satisfying § (b)(ii). Finally, as to best interests, the children (aged 17 and 15) expressed fear and anger toward the father, had stabilized in a relative placement, and needed permanency and safety. Their father’s disbelief and continuing cohabitation with the alleged abuser weighed heavily against reunification.