Removal under MCR 3.965(C)(2) & MCL 712A.13a(9); Foster care placement; Contrary-to-welfare finding; In re Benavides; Adequacy of findings for appellate review; In re Williams; Children’s Assessment Center (CAC)

The court held that the trial court made adequate findings under MCR 3.965(C)(2) and MCL 712A.13a(9) to support removing the children from respondent-mother’s care and placing them in foster care. CPS filed a petition alleging physical abuse and neglect, including reports that respondent hit the children with her hand and a broomstick, kept them from leaving the home, and left them alone for extended periods, and the investigation revealed a strong urine odor, traces of feces, hygiene concerns, and hazards such as “holes and exposed electrical wiring” in the children’s bedroom. The record also included missed medical care, school-attendance concerns, domestic-violence reports, CAC disclosures that the children witnessed violence between the parents, and disclosures that respondent struck two children with belts. After a preliminary hearing, the trial court authorized the petition and found that “taken together as sum” the circumstances supported removal, citing “poor conditions of the home,” lack of proof of improvement, an imminent utilities cutoff, “poor supervision,” and the “failure to meet medical needs[.]” It also identified “reasonable efforts” such as the DHHS and Families First involvement, referrals, drug screens, utility-bill assistance, and meetings. On appeal, the court explained that foster-care placement requires findings that custody presents a “substantial risk of harm,” that no reasonable services or arrangements short of removal can safeguard the children, that remaining in the home is “contrary to the child’s welfare,” that reasonable efforts were made to prevent removal, and that placement conditions are adequate. The court rejected the claim that the trial court relied only on a potential utility shutoff, stating the findings were supported by the CPS specialist’s testimony about living conditions, supervision failures, medical neglect, and domestic violence. The court also held the trial court was not required to “articulate extensive findings regarding every conceivable detail” and that its oral and written findings were “minimal but adequate” to permit meaningful appellate review, including explicit findings on contrary-to-welfare and reasonable efforts. Affirmed.