Child protective proceedings; Jurisdiction; In re Brock; MCL 712A.2(b)(1); Aggravated circumstances; Reasonable efforts toward reunification; MCL 712A.19a(2)(a); MCL 722.638(1)(a)(iii); Serious physical harm; MCL 722.622(ee); MCL 750.136b(1)(f); In re Barber/Espinoza; Termination of parental rights; §§ 19b(3)(b)(i) & (j); Child’s best interests; MCL 712A.19b(5); In re White; Relative placement; In re Olive/Metts

The court held that the trial court properly: 1) exercised jurisdiction, 2) found aggravated circumstances excusing reunification efforts, 3) found statutory grounds for termination under §§ (b)(i) and (j), and 4) determined that termination was in the child’s (VAT) best interests. Respondent-father’s rights were terminated after VAT testified that he sexually and physically abused her when she was a child, including touching her, punching her, cutting her, and burning her. The trial court exercised jurisdiction, found aggravated circumstances, and concluded termination was in VAT’s best interests. On appeal, the court first held that jurisdiction was supported under MCL 712A.2(b)(1) because VAT’s testimony showed she was subject to “a substantial risk of harm to . . . her mental well-being.” It next held that aggravated circumstances existed under MCL 722.638(1)(a)(iii) because VAT’s credible testimony that respondent punched, cut, and burned her showed abuse that included “serious physical harm.” The court rejected respondent’s statutory-grounds challenge because VAT’s testimony about inappropriate touching and physical abuse, her visible mark and scars, and the detective’s follow-up investigation supported § (b)(i), while the psychologist’s testimony that reunification would have a “detrimental impact” on VAT’s mental health supported § (j). Finally, the court held that termination was in VAT’s best interests because the trial court credited testimony that respondent did not prioritize VAT’s needs, found “no bond” between them, and considered her placement with her mother before concluding continued parental rights would place VAT at significant risk. Affirmed.