Termination under § 19b(3)(j); Whether reasonable reunification efforts were required; MCL 712A.19a(2)(c); Children’s best interests

The court held that the trial court did not clearly err in finding that (1) terminating respondent-mother’s parental rights was warranted under § (j), (2) reasonable reunification efforts were not required here, and (3) termination was in the children’s best interests. Thus, it affirmed the termination order. The court noted that the “children suffered nonaccidental trauma, and when asked about the trauma, respondents provided inconsistent stories to police and [DHHS], resulting in uncertainty in how the children were injured. Even if respondent-mother was not the direct cause of the injuries, she left the children in the care of someone who did injure [them], thereby failing to prevent the harm.” She also did not “participate in required services in past cases involving [DHHS], evidencing possibility of harm to the children in this case.” In addition, her “history with little-to-no change indicated that the children would be at risk of harm if returned to her care. This conclusion is supported by the clinical evaluation” that indicated, among other things, that she “did not fully appreciate the injuries to the children and the care they needed. Thus, it was not clearly erroneous for the trial court to find that” § (j) was established. As to reunification efforts, it was undisputed that she “had her parental rights to two children—siblings of the children in this case—terminated in the past.” Further, the clinical evaluation determined “that the conditions which led to the prior terminations, including serious and chronic neglect, improper supervision, threatened harm, and substance abuse, had not been rectified.” As to the children’s best interests, any parent-child bond was at best weak – they were in her “care for only two months before removal and parenting time had been suspended for over two years.” They had been in their current placement “for a majority of their lives, their foster parents are willing to adopt both of them and specifically provide for their medical needs. Adoption will provide the permanency and stability that the children need, emotionally and medically.”