Termination under § 19b(3)(j); Aggravated circumstances excusing reunification efforts; MCL 712A.19a(2)(a); MCL 722.638(1)(a)(iii); Anticipatory neglect; In re Kellogg; Parenting time suspension; MCL 712A.13a(13); In re Ott; Child’s best interests

The court held that the DHHS was not required to make reasonable reunification efforts because aggravated circumstances were established under MCL 712A.19a(2)(a) and MCL 722.638 based on severe abuse of the child’s sibling, that suspending parenting time was proper because contact “may be harmful” to the child, and that clear and convincing evidence supported termination under § (j) with termination serving the child’s best interests. The case arose from allegations that respondent-mother severely abused and neglected the child’s half-sibling, including extensive scarring and “skin injuries,” confinement, and a vitamin C deficiency causing scurvy, while the child lived in the same home and faced a risk of harm. The trial court authorized the petition, placed the child with relatives, suspended parenting time, and ordered no reunification efforts because it found “torture” conduct and other serious physical harm consistent with MCL 722.638(1)(a)(iii). On appeal, the court rejected respondent’s claim that MCL 712A.13a(13) was violated, explaining a parent is entitled to parenting time unless it “may be harmful to the juvenile’s life, physical health, or mental well-being,” and holding that the trial court did not err in finding even supervised contact could be harmful given the allegations, the ongoing criminal investigation at the outset, and the psychological harm of the child remaining connected to the environment where the sibling’s abuse occurred. The court then held that the aggravated-circumstances exception applied because respondent, an adult household caregiver, abused a sibling as defined by shared parentage, and the abuse included “battering, torture, or other serious physical harm,” supported by respondent’s admission she hit the sibling, the father’s admission he witnessed abuse and did not intervene, and medical testimony that the numerous scars were “highly concerning for non-accidental trauma” consistent with “a series of assaultive events.” Because those findings satisfied MCL 722.638(1) and (2), the DHHS was excused from reunification efforts, and termination at initial disposition was permissible. The court affirmed statutory grounds under § (j), applying anticipatory neglect because “abuse is abuse” and the severe, prolonged mistreatment of the sibling while the child lived in the home was highly probative of risk to the child despite differences in age, gender, and biological relationship. The court also affirmed as to best interests, finding no meaningful bond due to the long suspension of contact, respondent’s failure to engage in ordered evaluation and counseling, the child’s need for permanency, and the advantages of relative placement where the grandparents were providing stability and sought adoption. Affirmed.