Termination under § 19b(3)(c)(i); In re White; Reasonable reunification efforts; MCL 712A.13a(1)(d); In re Frey; Children’s best interests; In re Olive/Metts Minors

The court held that the DHHS made reasonable reunification efforts, that clear and convincing evidence supported termination under § (c)(i), and that termination of respondent-mother’s parental rights was in the children’s best interests. Before this case began, one of the children (MMJ) lived with his father and required 24-hour care because of significant medical and developmental needs. Then MMJ went into his grandmother’s care. The other child (MRB) lived with the mother until safety concerns led to MRB also being placed with the grandmother. The trial court later found jurisdiction because the mother had “abandoned” the children and suffered from “severe mental health and substance abuse issues.” After more than three years of noncompliance it terminated her parental rights. On appeal, the court held that the DHHS made reasonable efforts because it created a service plan with therapy, evaluations, drug screens, parenting classes, housing and income requirements, and visitation. It repeatedly attempted contact through “last known addresses, phone numbers, and relatives.” The court held that the mother, not the DHHS, was responsible for the lack of progress because she “never participated in any aspect of her case service plan” and failed to show that she “even tried to participate in or inform herself of the services being provided.” The court next held that the conditions of adjudication continued to exist because she failed to provide proper care or support and did not address her mental-health and substance-abuse issues despite ample “‘time to make changes and the opportunity to take advantage of a variety of services.’” It further held that termination was in the children’s best interests because the mother lacked a meaningful bond, failed to visit consistently, and could not provide the “care, permanency, stability, and finality” the children needed. Affirmed.