in Re Robinson Minors, 332844

Children removed in Feb 2015 after mother’s boyfriend sent two children out without winter clothing; children returned after >1 hour and were locked out; officers found mother asleep and discovered boyfriend in home; mother admitted drug use.
Foster placement revealed poor child care: CR and ZR had lice and decayed teeth; children reported physical abuse by the boyfriend; youngest child (BR) had developmental and behavioral issues.
DHHS provided services: counseling, drug screens, supervised/unsupervised parenting time, psychological evaluation, parent-mentor, housing and transportation assistance; mother initially made some progress but later disengaged.
From Oct 2015–Jan 2016 mother missed most drug tests, tested positive for marijuana, stopped counseling and AA, lost supervised-parenting supervisor after safety incidents, briefly obtained unsupervised visits but exposed children to boyfriend contrary to instructions.
Trial court terminated mother’s parental rights in April 2016 under MCL 712A.19b(3)(c)(i), (g), and (j); mother appealed arguing inadequate reunification efforts and that termination was not supported as to statutory grounds or best interests.

Issue	Respondent's Argument	DHHS/Trial Court's Argument	Held
Reasonable efforts for reunification	DHHS failed to provide psychiatric services and otherwise insufficient services	DHHS provided numerous services and arranged psychological evaluations; mother refused or delayed participation	Court: DHHS made reasonable efforts; evaluations did not recommend psychiatry and mother’s delay foreclosed additional services
Statutory grounds for termination (MCL 712A.19b(3)(c)(i))	Conditions could be remedied; mother showed some progress	Conditions that led to adjudication persisted and mother disengaged from services for 12+ months	Court: Clear and convincing evidence supports termination under (c)(i)
Statutory grounds for termination (g) and (j)	Mother challenged sufficiency	Mother failed to provide proper care, exposed children to abusive boyfriend, unresolved substance/mental-health issues creating likely harm	Court: Additional grounds (g) and (j) also satisfied
Best interests of the children	Mother argued recent efforts and differing needs required separate analyses	Children bonded with foster family, showed progress; mother’s engagement inconsistent and risk remained	Court: Preponderance supports termination; no reversible error in not making separate findings for each child

In re Fried, 266 Mich. App. 535 (2005) (standard for reviewing DHHS reasonable-efforts claim)
In re Plump, 294 Mich. App. 270 (2011) (agency must report efforts to rectify removal conditions)
In re Rood, 483 Mich. 73 (2009) (adequacy of services relevant to termination; State not required to provide every conceivable service)
In re LE, 278 Mich. App. 1 (2008) (DHHS must make reasonable efforts to reunify but not every service is required)
In re Terry, 240 Mich. App. 14 (2000) (limits on required services and review standard)
In re Frey, 297 Mich. App. 242 (2012) (parent’s duty to participate in offered services)
In re HRC, 286 Mich. App. 444 (2009) (termination proceedings may proceed when reunification services are no longer required)
In re Trejo, 462 Mich. 341 (2000) (standard of review for termination grounds and best-interest framework)
In re Olive/Metts Minors, 297 Mich. App. 35 (2012) (best-interest factors to consider)
In re JK, 468 Mich. 202 (2003) (failure to comply with parent-agency agreement evidences inability to provide proper care)