Termination under §§ 19b(3)(c)(i) & (j); Distinguishing In re LaFrance & In re Richardson; Ineffective assistance; Reasonable reunification efforts; In re Frey; Forfeiture; Best interests; Permanency & stability; Guardianship vs termination; MCL 712A.19a

The court held that statutory grounds for termination were established under §§ (c)(i) and (j) and that termination was in the children’s best interests. It also found that reasonable reunification efforts were made and it rejected respondent-father’s ineffective assistance of counsel claim. The DHHS filed the case after newborn-JG2 tested positive for meth and respondent-mother admitted using meth on the day she went into labor and again after discharge. She was homeless, unemployed, on parole, and had extensive CPS history including prior terminations and guardianships. The children were initially placed with the father under a safety plan barring the mother from residing in the home and requiring supervised contact. But unannounced CPS visits raised serious concerns, including a “strong chemical odor,” covered windows, acetone in the home, refusal to permit full inspection, and the mother answering the door while alone with the children while the father slept, with the mother admitting ongoing meth use and refusing a screen. Over nearly two and a half years, the mother’s compliance with services remained inconsistent, she failed to complete a psychological evaluation, continued positive or refused drug screens, failed to secure stable housing or employment, and stopped participating in supervised parenting time. The father completed limited services, tested positive for meth, and resisted agency involvement. Further, he made statements suggesting “he might go to the judge’s house, and admitted that he had driven by the foster care placement home.” The court concluded his counsel’s actions reflected reasonable strategy and the father could not show a different outcome given the record. His reasonable-efforts claim was unpreserved because he did not timely object to services and, in any event, the DHHS offered services and he did not meaningfully participate, so no error was shown. As to the mother, the court held the adjudicative conditions continued more than 182 days and were unlikely to be rectified within a reasonable time. It emphasized her ongoing meth use with direct harm reflected by JG2’s positive toxicology at birth and persistent instability. As to the best-interests findings, it noted the children’s lengthy time in care, the lack of meaningful bond, respondents' lack of verified sobriety and stability, and the strong need for permanency and safety. Affirmed.