Reasonable efforts to reunify; MCL 712A.18f; MCL 712A.19a; In re Hicks/Brown; Suspension of parenting time for harm risk; MCL 712A.13a(13); MCL 712A.18(1)(p); Conditions for parenting time; In re Ott; Traumatic brain injury (TBI)

The court held that the DHHS made reasonable reunification efforts and that the trial court did not abuse its discretion by suspending parenting time where contact risked harm to the child’s mental well-being. The case arose after respondent-mother, who has a history of TBI and significant mental health concerns, experienced a crisis that led to removal when CPS found her apartment in disarray with a white powder throughout, minimal food, and both respondent and the child with red irritated hands. Following services and later hospitalization with a very high blood alcohol level, parenting time was suspended due to the child’s severe dysregulation tied to visits and respondent’s instability. The trial court ultimately terminated under §§ (c)(i) and (j). On appeal, the court held that the DHHS satisfied its duty because it “must create a service plan outlining the steps that both it and the parent will take to rectify the issues that led to court involvement and to achieve reunification,” and the record showed respondent received extensive services and actively participated. The court also found that suspension of parenting time was proper because if the trial “court determines that parenting time, even if supervised, may be harmful to the juvenile’s life, physical health, or mental well-being, the court may suspend parenting time until the risk of harm no longer exists,” and the child consistently dysregulated around visits while respondent relapsed on alcohol. The court further approved conditioning parenting time on therapist approval and a therapeutic setting, noting the statute permits relying on a child’s counselor to determine “the appropriateness and the conditions of parenting time.” Affirmed.