Reasonable reunification efforts; MCL 712A.19a(2); Case service plan; In re Hicks/Brown; Parent participation & benefit; In re Frey; In re TK; Termination under § 19b(3)(j); Likelihood of harm; Emotional harm; In re Sanborn; Failure to comply with service plan; In re White; Children’s best interests; MCL 712A.19b(5); Permanency, stability, & finality; Individualized best-interest findings; In re Moss
The court held that DHHS made reasonable reunification efforts, that termination was proper under § (j), and that termination served the children’s best interests. The children were removed after domestic-violence and drug-use concerns, and respondent-father was ordered to participate in services addressing substance abuse, domestic violence, housing, and income. After multiple adjourned termination hearings, the trial court terminated the father’s parental rights. On appeal, the court first held that reasonable efforts were made because DHHS provided referrals and services for housing, employment, substance abuse, domestic violence, and supportive visitation, while the father only intermittently complied and still failed to “benefit from” many services. The court next held that § (j) was established because, despite “significant and commendable progress in achieving sobriety,” he still lacked child-appropriate housing, had not saved for a security deposit, had not progressed beyond supervised parenting time, and had not made meaningful progress on domestic-violence concerns, creating a reasonable likelihood of harm if the children were returned. The court also held that termination served the children’s best interests because the foster home provided “‘consistency, structure, security, love, affection,’” the older child was “begging for this to be done and get permanency,” the younger child had been in care for about half her life, and the trial court properly gave greater weight to permanence, stability, and finality than to the children’s bond with the father. Affirmed.
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