Background
Michigan’s Department of Health and Human Services became involved after repeated domestic-violence incidents between the respondent father and the children’s mother occurred in the children’s presence. Two children were removed from the father’s care in April 2023, and a third child, born while the case was pending, was later removed as well. The father was ordered to participate in services addressing parenting skills, mental health, domestic violence, housing, and other barriers to reunification.
After nearly two years, DHHS sought termination. Evidence showed that the father missed many parenting-time sessions, did not complete required services, resisted sharing information about his mental-health treatment, remained emotionally combative, and had not obtained suitable housing. Witnesses also reported that the children exhibited dysregulated, self-injurious, or violent behavior after visits. The trial court terminated his parental rights under MCL 712A.19b(3)(c)(i), finding that the conditions leading to adjudication remained and that termination served each child’s best interests.
The Court’s Holding
The Court of Appeals affirmed. It held that the trial court did not clearly err by finding that DHHS made reasonable reunification efforts, including accommodations responsive to the father’s mental-health challenges. The father had assistance from a guardian ad litem and a Pathways case manager, and DHHS offered or facilitated parenting time, parenting classes, housing assistance, transportation support, counseling, and psychiatric services. The father did not identify a necessary accommodation that would have produced a better outcome.
The court also upheld the best-interests findings for all three children. The record supported findings that the father lacked strong bonds with the children, could not provide needed consistency and stability, and had not meaningfully complied with the service plan. Meanwhile, the children were improving and thriving in foster care, and their foster parents were willing to adopt them. Because the evidence supported the individualized findings for each child, the trial court did not clearly err.
Key Takeaways
- A parent challenging reunification services must identify deficient services or accommodations and show that different services likely would have produced a better result.
- DHHS’s reasonable-efforts obligation does not eliminate a parent’s corresponding duty to participate in and benefit from offered services.
- Missed visits, incomplete services, unsuitable housing, limited parent-child bonds, and the children’s progress in foster care supported termination as being in each child’s best interests.
Why It Matters
The decision illustrates how Michigan courts assess reasonable reunification efforts when a parent asserts mental-health disabilities. Providing support tailored to known challenges may satisfy the state’s obligation when the parent does not explain what additional accommodation was necessary or demonstrate that it would have improved the likelihood of reunification.
It also reinforces that best-interests review centers on each child’s needs for safety, stability, and permanency—not solely on the parent’s efforts—and that courts may weigh the children’s reactions to visitation and improvement in foster care.