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

The court held that the trial court did not err in finding reasonable reunification efforts, that § (c)(i) was established, and that termination was in the children’s best interests. The case arose from severe medical neglect that resulted in one child requiring resuscitation after untreated respiratory illness. The DHHS provided services including parenting classes, psychological and medical evaluations, and transportation assistance. On appeal, the court held that the reasonable-efforts claim failed because the DHHS provided extensive accommodations, including “direct transportation . . . [which] was not a ‘normal’ service,” and respondent failed to show she “‘would have fared better if other services had been offered.’” The court next held that § (c)(i) was proven because respondent “did not accomplish any meaningful change in the conditions” despite three years of services and continued inability to manage medical care, and there was “no reasonable likelihood” the conditions would be rectified within a reasonable time. Finally, the court held that termination was in the children’s best interests, emphasizing their progress and stability in placement, that one child’s “severe emotional responses” were triggered by respondent, and that the caregiver was meeting all needs and “willing to adopt,” making permanency, stability, and finality outweigh any prior bond. Affirmed.