Reasonable reunification efforts; MCL 722.638(1)(a)(iii); Aggravated circumstances; Termination under §§ 19b(3)(b)(i), (j), (k)(iii), & (k)(iv); Children’s best interests; Bond with the children; Incarceration

The court held that because the trial court found respondent-father subjected the child (CJC) to abuse involving “battering, torture, or other serious physical harm,” it did not err by concluding “reasonable efforts toward reunification were not required.” The court also rejected his claim that the trial court erred in finding “one or more statutory grounds for termination was established.” Finally, it determined the trial court did not when it found that termination was in both children’s best interests. Respondent first argued “that the trial court erred when it terminated his parental rights because [it] did not order that the [DHHS] offer services toward reunification or make findings of aggravated circumstances such that the services were not required to be offered.” He argued “that, while the trial court discussed the seriousness of CJC’s injuries, and respondent’s failure to seek prompt emergency medical care, it never connected those fact to a formal finding of aggravating circumstances.” While respondent was “correct that, on the record, the trial court did not specifically link its findings that respondent had physically abused the child to its decision to not order reasonable efforts toward reunification, respondent does not offer this Court any authority that such a specific statement on the record is required. ‘[W]here a party fails to cite any supporting legal authority for its position, the issue is deemed abandoned.’” The court held that even “if the issue was not abandoned, this Court is not aware of any authority for respondent’s proposition. In the order of disposition, the court stated that it was not ordering the [DHHS] to offer services toward reunification because of respondent’s conviction of third-degree child abuse.” The trial court also made findings that respondent “intentionally caused serious harm to CJC and caused the loss or impairment to one or more of his limbs. There also did not appear to be any confusion among trial counsel” that the DHHS “was not offering services and that the court made findings relative to the injuries suffered by the children.” Next, respondent argued that the trial court “erred because there was not clear and convincing evidence that one or more statutory grounds for termination was established.” The trial court terminated his rights under §§ (b)(i), (j), (k)(iii), and (k)(iv). Respondent accurately noted “that the trial court relied on the testimony of Drs. [B] and [S] when concluding that CJC’s burns were nonaccidental.” Contrary to his “suggestion in his brief on appeal, neither [doctor] equivocated that the large burns on CJC’s legs were the result of an immersion injury that was indicative of a ‘controlled event.’” The court noted that “the trial court disagreed with respondent’s argument that the medical doctors were conflicted in their diagnosis of the source of CJC’s burns.”