in Re Williams Minors, 332633

Two children (MDW and CTW) were the subjects of termination proceedings; parents (respondent-mother and respondent-father) appeal the trial court’s termination order.
Trial court terminated parental rights under multiple statutory grounds, including MCL 712A.19b(3)(c)(i), (c)(ii), (g), (j), and additionally (i) and (l) as to the mother.
Respondent-mother has documented intellectual/mental limitations; the trial court appointed a limited guardian ad litem (L‑GAL) and ordered specialized services (Neighborhood Service Organization behavioral parenting classes).
The mother’s counsel mentioned limitations but never asserted an ADA violation before the trial court; she later argued on appeal that DHHS failed to reasonably accommodate her disability under the ADA.
Both parents largely failed to complete their parent-agency agreements, did not learn sign language for MDW (who is deaf and has mild cerebral palsy), and did not consistently attend medical appointments; parenting time was problematic and bonds were weak.
The trial court found DHHS made reasonable accommodations and concluded termination was in the children’s best interests; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DHHS failed to make reasonable ADA accommodations for mother	Mother: DHHS did not reasonably accommodate her disability under the ADA, invalidating reunification efforts	DHHS/State: DHHS and the court provided accommodations (L‑GAL, specialized services, tailored casework)	Affirmed: No error; record shows reasonable accommodations were made; ADA claim was unpreserved and fails on the merits
Whether statutory grounds for termination were proven	Mother: Termination under listed subsections was improper (including due process challenge to §(l))	State: Statutory grounds were established; mother stipulated to multiple grounds	Affirmed: Mother stipulated to many grounds; issue waived, court did not need to address §(l) challenge
Whether termination was in the children’s best interests	Parents: Termination not in children’s best interests	State: Children needed permanency; parents failed services, poor bonding, unmet needs (medical, communication)	Affirmed: Trial court's best‑interest finding not clearly erroneous; preponderance supports termination
Whether ADA can be used as defense to termination	Mother: ADA violation bars termination or shows inadequate reunification efforts	State: ADA is not a defense to termination but requires reasonable accommodations in services	Held: ADA not a termination defense; but DHHS must accommodate — here accommodations were adequate and issue unpreserved

In re TK, 306 Mich App 698 (preservation and review of issues in termination appeals)
In re Terry, 240 Mich App 14 (ADA requires reasonable accommodations by public agencies in reunification services)
In re Hudson, 294 Mich App 261 (waiver of appellate arguments when not raised below)
People v Carines, 460 Mich 750 (plain‑error review standard)
In re Trejo, 462 Mich 341 (standard of appellate review for best‑interest findings)
People v Kurylczyk, 443 Mich 289 (definition of clear error)
In re Moss, 301 Mich App 76 (preponderance standard for best‑interest determination)
In re Olive/Metts, 297 Mich App 35 (factors for best‑interest analysis)
In re Payne/Pumphrey/Fortson, 311 Mich App 49 (consideration of length in care and likelihood of return)
In re Frey, 297 Mich App 242 (factors related to reunification prospects)
In re White, 303 Mich App 701 (considering child’s well‑being and adoption potential)