Background
The Michigan Department of Health and Human Services took custody of respondent-mother’s four children in October 2024 after she overdosed while caring for them. The removal also followed concerns about domestic violence, deplorable housing conditions, unmet basic needs, and inadequate care for the three oldest children, all of whom had been diagnosed with autism. The mother later was convicted of fourth-degree child abuse and neglect.
The mother pleaded to jurisdiction, and the court identified unsuitable housing, substance abuse, mental-health issues, improper resource management, and inadequate parenting skills as barriers to reunification. After she made little progress, failed to communicate consistently with the department, and was sentenced to seven months in jail, the court changed the permanency goal to adoption. In October 2025, the trial court terminated her parental rights under MCL 712A.19b(3)(c)(i) and (j), finding that the relevant conditions persisted, the children risked harm if returned, and termination served their best interests.
The Court’s Holding
The Court of Appeals affirmed. Reviewing the mother’s unpreserved reasonable-efforts challenge for plain error, the court held that the department offered adequate reunification services, including help locating housing and rehabilitation programs, supervised parenting time, family-team meetings, and mental-health and substance-abuse counseling. The mother did not meaningfully participate for more than six months, declined assistance obtaining Medicaid after insurance problems prevented admission to one rehabilitation facility, and received additional housing resources when she requested them.
The court also held that clear and convincing evidence supported termination under MCL 712A.19b(3)(c)(i). More than 182 days had elapsed since the initial dispositional order, and although the mother completed a 30-day rehabilitation program and had achieved a brief period of sobriety, she lacked housing and income, had not demonstrated sustained sobriety, and had made insufficient progress on her service plan. Because one statutory ground was sufficient, the court did not decide whether subsection (j) was independently established.
Finally, the court found no clear error in the best-interest determination. The children needed permanence and stability, could not foreseeably be returned to the mother, and were having their needs met in a preadoptive foster placement. Although the youngest child was bonded to the mother, that bond did not outweigh the considerations favoring termination. Separate findings for every child were unnecessary because their relevant interests and needs did not significantly differ.
Key Takeaways
- A parent who does not timely object that reunification services are inadequate generally receives only plain-error review on appeal.
- The department made reasonable efforts by offering services and practical assistance; the parent had a corresponding obligation to participate and benefit from them.
- Brief sobriety and completion of a short rehabilitation program did not overcome continuing problems with housing, income, sustained sobriety, and compliance with the service plan.
- A court need not make redundant child-by-child best-interest findings when the children’s relevant interests do not significantly differ.
Why It Matters
The unpublished decision illustrates that the reasonable-efforts inquiry considers both the services offered by the department and the parent’s response to them. A parent’s failure to communicate, accept assistance, or participate meaningfully can defeat a later claim that the department did too little.
It also confirms that a parent-child bond, standing alone, does not preclude termination when the record shows persistent barriers to reunification and a preadoptive placement that provides the children with needed stability and care.