Reunification efforts; Suspension of parenting time; Due process; Parent’s removal from the home; MCL 712A.13a(4); Availability of an appeal; MCR 3.993(A)(1)

Rejecting respondent-mother’s claims (1) that the DHHS and the trial court impeded her efforts to reunify with her children and (2) that she was denied due process related to her removal from the family home, the court affirmed the order terminating her parental rights. It noted that she “received a trauma assessment, individual and family counseling, trauma-informed parenting classes, case management, and supportive visitation services.” Her two children were also “provided with trauma assessments, and family team meetings were held regularly to determine family supports and needs.” Thus, the court found she “and her children were offered a wide range of services in an effort to accomplish reunification.” Further, the record showed that respondent “participated in services, but she did not benefit from” them. She asserted that “the trial court prevented her from demonstrating the parenting skills she had learned by suspending her parenting time. At the time of the suspension, [she] had been exercising parenting time for almost one year. Despite consistently attending and participating in parenting” classes, she failed to show any benefit. The court found that her “failure to benefit from services, rather than any lack of reasonable efforts by the DHHS or interference by the trial court, was the barrier that prevented reunification.” She next argued that “she should have been given the same opportunity to appeal her removal from the home as she would have been afforded to appeal the removal of her children from the home.” But she did not “identify any error in the trial court’s determination to remove her, much less anything sufficient to reverse that decision on appeal. Thus,” the court found “no error at all, much less plain error, in the trial court’s decision to remove her from the home pursuant to MCL 712A.13a(4). Accordingly, any appeal of that ruling, whether immediately after her removal from the home or at any later point, would have been unsuccessful.” The court added that she could have appealed that order of right under MCR 3.993(A)(1).