Best interests; MCL 712A.19b(5); In re Johnson; Reasonable efforts; MCL 712A.19a(2); In re Rippy

The court held that the trial court did not err by finding termination was in the child’s (AM) best interests and that the DHHS was not required to provide reunification services. After respondent-father was convicted of CSC I and child abuse involving AM’s sibling, he pled no contest to jurisdiction and stipulated to statutory grounds, leaving only best interests. The court emphasized AM’s need for “finality and permanence” given respondent’s incarceration and AM’s expressed wishes. It noted AM told the caseworker he “wanted to move on” and that respondent admitted he “no longer had any bond” with AM. The panel rejected respondent’s argument that his prison term eliminated danger, explaining that long incarceration still supports termination because a child needs stability, citing Johnson. It also relied on evidence of the home environment and risk, including a psychological report concluding that no child “would be safe in the care of respondent,” that respondent had a “high risk for sexual offensive recidivism,” and that the family lived in an “environment of fear.” On reasonable efforts, the court held the issue failed under MCL 712A.19a(2) because aggravated circumstances applied where respondent was convicted of CSC involving penetration against AM’s sibling, and it noted that such findings “amount to a judicial determination” excusing services, citing Rippy. It also noted reunification efforts were excused because respondent was ordered to comply “with Sex Offender Registration.” Affirmed.