Adjudication; MCL 712A.2(b)(1); Plea; MCR 3.971(B) & (D); Reasonable reunification efforts; A respondent’s “commensurate responsibility” to participate in the offered services; Due process; Notice of what was expected of respondent

The court upheld the trial court’s exercise of jurisdiction, concluded that the DHHS made reasonable reunification efforts, and found no merit in respondent-father’s claim that ‘he lacked notice of what was expected of him in the” proceedings. Thus, it affirmed the trial court’s order exercising jurisdiction and its later order terminating his parental rights. As to the adjudication, the court concluded that because “the referee complied with the relevant portions of MCR 3.971(B) and (D) to ensure the plea was voluntarily and knowingly made, the manner in which the trial court assumed jurisdiction did not violate” respondent’s due-process rights. As to the trial court’s decision to exercise jurisdiction, respondent’s admissions supported “that, when able to do so, he neglected or refused to provide proper or necessary support for the minor child under MCL 712A.2(b)(1). [He] admitted he was aware of the child protective proceedings.” But as of 3/26/24, “he had not communicated with ‘the assigned worker’ to address the” child’s needs since 7/14/23. Respondent also admitted, on 11/1/23, that he established himself as the “child’s legal father through an affidavit of parentage.” As of 3/26/24, he “admitted that he lacked income and housing that was appropriate for his and the” child’s needs. The court held that these “admissions established, by a preponderance of the evidence” that the child needed more care than respondent could provide. It determined that the trial court’s finding was “consistent with ‘the underlying purpose of the statutory scheme,’ which ‘is to protect children from an unfit homelife.’” The court next held that the trial court did not err in finding that respondent “was provided with services to aid in reunification.” Contrary to his appellate arguments, “he was provided sufficient time to participate in, and benefit from, services. However, he failed to uphold his ‘commensurate responsibility’ to participate in the services offered by DHHS.” Further, there was no indication he “would have fared better if DHHS had offered other services, or accommodations, to assist him.” Finally, the court found that the DHHS did not fail to notify respondent “of what was required in order to preserve his parental rights. He was not deprived of the fundamental fairness required for due process.”