Termination under §§ 19b(3)(c)(i), (g) & (j); Children’s best interests; MCR 3.977(I)(1); Reasonable reunification efforts; Failure to participate in services; In re White; Case-service plan (CSP)

The court held that the trial court did not err in finding that reasonable reunification efforts were made and that §§ (c)(i), (g), and (j) supported terminating respondent-mother’s parental rights. As to the children’s best interests, it found that “the trial court satisfied MCR 3.977(I)(1).” Thus, it affirmed the termination order. As to the children’s best interests, her “argument that the stipulated order cannot satisfy MCR 3.977(I)(1)’s requirement that the trial court ‘state on the record or in writing its findings of fact and conclusions of law’ fails, because the parties manifestly agree, by virtue of the signed, stipulated order itself, that the [trial] court did ‘state on the record’ [its] findings of fact and conclusions of law. Moreover, the stipulated findings adequately addressed the children’s best interests, including adoptability, developmental needs, medical complexity, placement stability, and mother’s failure to benefit from services.” As to reasonable efforts, the trial court ordered the mother “to participate in a CSP. DHHS referred [her] for therapy, parenting classes, parent partner services, housing assistance, visitation, and medical education. Over nearly two years, [she] was terminated from services due to nonparticipation, declined re-referrals, failed to attend visits and appointments, and did not meaningfully engage in the services ordered. DHHS additionally accommodated transportation barriers, facilitated virtual medical attendance, provided educational resources, and transported [her] and the children for supervised parenting time visits. Despite these efforts, [she] attended only two of over one hundred medical appointments and completed only nine parenting time visits in 32 months. [Her] failure to participate supported statutory grounds for termination under” §§ (g) and (j). The court added that, apart from “her noncompliance with the CSP, the original neglect was severe. MH went a year without medical care, failed to gain weight, and had a dislodged feeding tube. AH was profoundly malnourished. As the trial court found, without intervention,” they would have died. While the “mother claimed recent improvements in housing and transportation, those late and unverified efforts do not outweigh her persistent inability to meet the children’s medical needs.”