Child protective proceeding; Reasonable efforts; MCL 712A.19a(2); In re Hicks/Brown; Statutory grounds; MCL 712A.19b(3)(c)(i); In re Atchley; Children’s best interests; MCL 712A.19b(5); In re Sanborn

The court held that DHHS made reasonable reunification efforts, that clear and convincing evidence supported termination, and that termination was in the children’s best interests. Respondent-mother’s children were removed 6/23 after allegations of neglect and improper supervision, domestic violence in the home, and the youngest child’s birth positive for multiple illegal substances with withdrawal symptoms after the mother admitted using meth, cocaine, and marijuana during pregnancy. The trial court assumed jurisdiction in 1/24 and later terminated the mother’s parental rights after she continued to struggle with substance abuse despite services. On appeal, the court held that the DHHS made reasonable efforts because it provided a substance-abuse assessment, drug screens, parenting classes, domestic-violence treatment, and mental-health services, and the mother failed to show what additional bipolar-disorder services would have changed the outcome. The court noted it was “left to speculate” what other services the DHHS could have offered and that the mother had to both participate and benefit. It next held that the conditions of adjudication continued to exist because the mother made only minimal progress on substance abuse, repeatedly tested positive for multiple substances, stopped regular screening, and failed to complete recommended inpatient treatment. The court finally held that termination served the children’s best interests despite their bond with the mother and relative placement because the children needed permanence, had been in family care for most of the case, were bonded with their great aunt, and adoption was available. Affirmed.