Whether reasonable efforts were required; MCL 712A.19a(2)(c); Aggravated circumstances; MCL 722.638(1)(a)(iii); Americans with Disabilities Act (ADA); ADA accommodations; In re Hicks/Brown; Child’s best interests; Relative placement; In re Olive/Metts

The court held that reasonable efforts toward reunification were not required, that respondents failed to show an ADA-based defect warranting relief, and that termination was in the children’s best interests. Respondent-mother and respondent-father pled no contest to jurisdiction and statutory grounds for termination after evidence showed serious physical abuse, malnutrition, domestic violence, and prior terminations. The trial court found aggravated circumstances, suspended contact after respondents arrived at the placement while the father was drunk and armed, and terminated their parental rights after a best-interest hearing. On appeal, the court first held that DHHS was not required to make reasonable efforts because both parents had prior terminations and failed to rectify the conditions, and the trial court made a judicial determination that the children were subjected to “torture and battery.” It further held that, even assuming efforts were required, the mother waived the ADA issue by omitting it from her questions presented, and the father failed to identify services that would have accommodated his disability beyond those offered. The court noted that workers provided transportation assistance, “overexplain[ed] everything,” helped with paperwork, and offered services consistent with the father’s evaluation. The court next held that termination was in the children’s best interests. The mother showed “poor decision-making,” hit the children during parenting time, failed to resolve domestic violence, and lacked a meaningful bond with two of the children. The father had “violent tendencies,” failed to accept responsibility, and had a pattern of domestic violence and poor parenting. The children were improving in a relative placement, who wished to adopt them and provide permanence with the siblings together. Affirmed.