Termination at initial disposition; Reasonable efforts; Aggravated circumstances; MCL 712A.19a(2)(a); MCL 722.638(1)(a)(ii); In re Simonetta; Termination under § 19b(3)(k)(ii); Anticipatory neglect; In re Kellogg; Children’s best interests; Relative placement; In re Olive/Metts

The court held that the trial court did not err by terminating respondent-father’s parental rights at the initial disposition without requiring reasonable reunification efforts. Respondent sexually abused the children’s half-sibling, PR. The court explained that reasonable efforts are not required when aggravated circumstances exist, including “criminal sexual conduct involving penetration, attempted penetration, or assault with intent to penetrate.” The court deferred to the trial court’s credibility finding that PR testified credibly and respondent was “just simply not credible,” noting the trial court had “no doubt” respondent “groomed” PR and carried on a sexual relationship with her “for a long period of time.” The court next held that § (k)(ii) supported termination because PR gave “extensive testimony concerning respondent’s sexual penetration of her,” and the trial court found “the risk that one or both of these children could also be sexually abused” was “unreasonably high.” Relying on anticipatory neglect, the court reasoned that a parent’s treatment of one child is “probative of how that parent may treat other children.” Finally, the court held that termination was in the children’s best interests because the trial court considered their bond with respondent, safety, relative placement, future risk, and excitement about reunification with their mother. The court also rejected respondent’s relative-placement argument because the trial court expressly found placement with the mother, even though she was a relative, did not “work against” termination. Affirmed.