Reasonable reunification efforts; MCL 712A.19a(2)(a); Lack of a finding of aggravated circumstances; Lawyer-guardian ad litem (LGAL)

In an order in lieu of granting leave to appeal, the court vacated the Court of Appeals judgment (see eJournal # 84396 in the 10/3/25 edition) and remanded the case to that court “to consider whether reasonable reunification services were rendered and, if [they] were not rendered, to determine the appropriate remedy for the lack of a judicial determination of aggravated circumstances.” It noted that the DHHS “must make reasonable efforts to reunify the child and family in all cases unless ‘[t]here is a judicial determination that the parent has subjected the child to aggravated circumstances as provided in [MCL 722.638(1) and (2)].’” Both the DHHS and the children’s LGAL conceded “that no such judicial determination was made.” There was a dispute as to whether reasonable efforts were actually made in the case. “If necessary to the proper resolution of this case, the Court of Appeals may remand to the trial court for additional fact-finding.” The court directed the Court of Appeals to “expedite its consideration of this case.”