Termination under § 19b(3)(c)(i); Reasonable reunification efforts; MCL 712A.18f; Parenting time; Americans with Disabilities Act (ADA) accommodations; In re Hicks/Brown; Children’s best interests; Relative placement & guardianship; In re Olive/Metts

The court held that the trial court did not err in finding that § (c)(i) supported termination, that reasonable reunification efforts were made, and that termination was in the children’s best interests. The DHHS sought termination after repeated removals stemming from respondent-mother’s physical abuse and ongoing mental-health and substance-abuse issues, and respondent-father’s failure to provide care or engage in services. On appeal, the court held that § (c)(i) was established because “the conditions that led to the adjudication continued to exist” and there was “no reasonable likelihood” of rectification within a reasonable time. It emphasized respondent-mother’s lack of emotional regulation and the psychologist’s finding that she “showed no empathy” and was “not recommended” as a custodial parent. The court next held that reasonable efforts were made, explaining that the DHHS’s approach to parenting time (allowing the children discretion) was appropriate where it was found that forced contact would be harmful. Further, the mother failed to show she “would have fared better if other services had been offered,” including regarding her alleged reading disability and cancer-related limitations. Finally, the court held that termination was in the children’s best interests, noting their weak or deteriorating bonds with respondents, their need for “permanency, stability, and finality,” and that their relative placement was meeting all needs and “willing to adopt.” In this case, the relative placement did not weigh against termination. Affirmed.