in Re mickaels/baldwin Minors, 329364

DHHS became involved after unsafe housing and a 2011 police raid found meth production; children JJ and JL were removed; father imprisoned for meth production.
JJ later disclosed that respondent’s then-boyfriend forced him to have anal sex with respondent when JJ was five; boyfriend pleaded guilty to second-degree criminal sexual conduct and testified at respondent’s termination hearing.
Respondent had unstable housing, unemployment, cognitive limitations, and a history of victimization; she declined some offered help (including assistance applying for SSI) and made minimal demonstrated parenting progress despite services.
Children JJ and JL were removed again after cigarette burns on JJ; respondent had limited contact with the younger children and did not complete required programs or fully participate in specialized assessments and medical appointments.
The trial court found multiple statutory grounds for termination of respondent’s parental rights to four children and found, by a preponderance, that termination served the children’s best interests; respondent appealed only the reasonable-efforts and best-interests findings.

Issue	Respondent's Argument	DHHS / Trial Court Argument	Held
Whether DHHS failed to make reasonable efforts to reunify	DHHS should have given more explicit, detailed parenting instruction and actively helped with SSI application given respondent’s cognitive limitations	DHHS provided parenting classes, counseling offers, and assistance; respondent declined some help and failed to benefit from services	Court affirmed: DHHS made reasonable efforts; respondent must participate in services and show ability to meet children’s basic needs
Whether termination was in children’s best interests	Termination improper because of alleged insufficient reunification efforts	Children needed permanency, had weak bonds with respondent, respondent unsafe/unemployed/unstable; foster and relative placements provided stability and willingness to adopt	Court affirmed: termination was in children’s best interests given safety, bonding, stability, and unlikely reunification in foreseeable future

In re Mason, 486 Mich. 142 (recognizing when reasonable efforts to reunify may be excused)
In re Rood, 483 Mich. 73 (agency not required to provide every service the parent requests to avoid termination)
In re Terry, 240 Mich. App. 14 (parent must demonstrate ability to meet children’s irreducible minimum parental responsibilities)
In re Olive/Metts, 297 Mich. App. 35 (factors for best-interests analysis: bond, parenting ability, need for permanency and stability)
In re Frey, 297 Mich. App. 242 (parents must participate in offered services; court may consider foreseeable return timeline)