Termination at the initial disposition; MCL 712A.19a(2)(c); §§ 19b(3)(c)(i), (i), & (j); Children’s best interests; Reasonable reunification efforts; Accommodations under In re Hicks/Brown

In these consolidated appeals, the court held as to respondent-father that the trial court did not clearly err in finding §§ (i) and (j) were established and in terminating his parental rights at the initial disposition. As to respondent-mother, the trial court did not clearly err in finding the DHHS made reasonable reunification efforts and accommodations, or in concluding that § (c)(i) was established. It also did not clearly err in determining that terminating both respondents’ rights was in the children’s best interests. As to the father, the trial court properly concluded “that reasonable efforts were not required” in light of the prior “termination of rights to his other child and his failure to rectify the conditions that led to that termination.” As to statutory grounds, it “did not clearly err by finding that [his] parental rights had been terminated to [one child’s] siblings under circumstances that may be characterized as ‘serious and chronic neglect or physical or sexual abuse,’ and that he had failed to rectify the conditions that led to those terminations.” Further, respondent “had a significant history of substance abuse and domestic violence.” While he obtained employment and housing, there was “no indication that he had addressed his anger issues.” As to the mother, the DHHS twice referred her to supportive visitation, but she did not participate. She “completed some counseling and other services before she was incarcerated, as well as at least some parenting education. Had [she] completed her second psychological evaluation, however, or consistent counseling” she may have obtained the added services she identified at trial to help her with one child’s special needs. As to statutory grounds, the court held that “the trial court did not clearly err by finding that the conditions that led to the adjudication continued to exist.” Further, given her “limited participation in services and progress, the trial court did not clearly err by finding that [she] would not rectify the conditions that led to adjudication in a reasonable time.” Affirmed.