Background
Child-protective proceedings began after repeated domestic-violence incidents between the respondent father and the children’s mother, including altercations in the children’s presence. Two children were removed in April 2023, and a third child, born while the case was pending, was later removed. The father was ordered to participate in parenting education, mental-health treatment, a psychological evaluation, domestic-violence programming, and supervised parenting time.
Over nearly two years, the father had a contentious relationship with caseworkers, attended only a fraction of the offered parenting-time sessions, did not complete required programming, resisted releases allowing the agency to verify services, and failed to obtain suitable housing. The trial court found the agency’s witnesses more credible, determined that the conditions leading to adjudication remained unresolved, and terminated his parental rights under MCL 712A.19b(3)(c)(i). The father appealed the reasonable-efforts and best-interest findings but did not challenge the statutory ground for termination.
The Court’s Holding
The Court of Appeals affirmed, holding that the trial court did not clearly err by finding that the Michigan Department of Health and Human Services made reasonable efforts toward reunification. Although the father cited several mental-health diagnoses and argued that the agency failed to accommodate his disabilities, he did not identify necessary accommodations that would have improved his ability to overcome the reunification barriers. The record showed that he received assistance from a guardian ad litem and a Pathways case manager, as well as mental-health, parenting, transportation, housing, and visitation-related support.
The court also rejected the father’s specific complaints about parenting time, parenting classes, housing and financial assistance, and the psychological evaluation. The record showed that the agency changed visitation arrangements, offered gas cards and information about free WiFi, sought parenting-class options, helped with housing resources, and repeatedly requested a psychological evaluation. Many difficulties resulted from the father’s refusal or failure to participate, his conduct toward caseworkers, or his resistance to sharing information about his services.
The court further held that a preponderance of the evidence supported the finding that termination served each child’s best interests. The children lacked a strong bond with the father, displayed behavioral dysregulation after visits, needed consistency and stability that he could not provide, and were improving in foster care. Their foster parents were willing to adopt them and provide permanency.
Key Takeaways
- A parent challenging reunification services must identify needed accommodations and show that different services likely would have produced a better outcome.
- DHHS’s reasonable-efforts obligation is paired with the parent’s responsibility to participate in and benefit from the services offered.
- The children’s limited bond with the father, adverse reactions after visits, progress in foster care, and need for permanence supported the best-interest determination.
Why It Matters
The decision illustrates how Michigan courts evaluate disability-accommodation arguments in termination cases. A diagnosis alone does not establish that reunification efforts were unreasonable; the parent must connect the disability to a necessary modification and demonstrate how that modification could have helped address the barriers to reunification.
It also underscores that best-interest review focuses on each child’s circumstances rather than the parent’s isolated efforts. Inconsistent visitation, failure to benefit from services, and the children’s demonstrated need for stability may support termination when the record also shows that they are thriving in a prospective adoptive placement.