Termination under §§ 19b(3)(c)(i), (g), & (j); Reasonable reunification efforts; MCL 712A.18f; In re MJC; Ineffective assistance of counsel; Failure to object; People v Abcumby-Blair; Children’s best interests; Individualized findings; In re Olive/Metts Minors

The court held that: 1) the DHHS made reasonable reunification efforts, 2) respondent-mother was not denied the effective assistance of counsel, 3) statutory grounds supported termination, and 4) termination was in the children’s best interests. The DHHS petitioned after the mother had untreated mental-health concerns, unstable housing, a history of domestic violence, prior CPS involvement, and a prior termination. Substance abuse later became an additional barrier when a child tested positive for cocaine and amphetamines at birth. On appeal, the court first held that the trial court did not err by finding reasonable efforts because the “DHHS prepared and updated case service plans pursuant to MCL 712A.18f(2) and (5),” the parties had the reports during the proceedings, and the DHHS offered “individual therapy, parenting classes, parenting time, domestic violence counseling, substance abuse testing, and a variety of referrals for employment and housing assistance.” The court emphasized that the mother “was offered a plethora of services” but “simply failed to consistently engage in, or benefit from, them.” The court also found no ineffective assistance from counsel’s failure to object to the service-plan issue because the plans existed and the mother could not establish prejudice. As to statutory grounds, the court held that the case lasted more than three years, the DHHS offered services, and the mother “continued to abuse substances and be with partners who perpetrated violence against her[.]” Finally, the court held that termination was in the children’s best interests because the trial court “specifically acknowledged” the need for an individual analysis, considered each child’s bond or lack of bond, and found that “the children needed ‘stability and permanence to break the cycle.’” Affirmed.