Termination at initial disposition; MCL 712A.19a; In re Hicks; Aggravated circumstances; Permanency planning hearing compliance; In re Rood; Best interest factors; Relative placement consideration; MCL 712A.19b; In re Gonzales/Martinez; Relative-placement investigation duty; MCL 722.954a

The court held that the trial court did not err by proceeding to terminate parental rights at the initial disposition stage or by finding termination was in the children’s best interests. The case began after one child was hospitalized with severe burns over roughly 16% to 17% of her body, and a second child was removed shortly after birth given the prior injuries and respondent-mother’s domestic-violence history. The trial court ordered reunification services while criminal charges were pending, and respondent participated within those constraints, later pleading guilty to first-degree child abuse and receiving a prison sentence. On appeal, the court rejected a procedural challenge based on aggravated circumstances and permanency planning because reasonable efforts were not withheld, hearings were held within the statutory framework, and the record made aggravated circumstances apparent in light of the felony conviction tied to serious injury. The court also declined a timing argument about initial-disposition termination where the rule’s substantive prerequisites were satisfied. On best interests, the court emphasized the child-centered focus, the need for permanency and safety, the limited bond with the younger child, and the conclusion that maintaining a bond with the injured child was not realistically achievable given the admitted abuse. The court further held the trial court considered relative placement and sibling-relationship implications, and the agency’s early relative outreach met statutory expectations on this record. Affirmed.