Termination under §§ 19b(3)(c)(i) & (j); The adjudicative & dispositional phases; In re Sanders; Admissibility of evidence; MCR 3.977(F); MCR 3.977(H)(2); In re Jenks; “New” or “different”; In re Snyder; Reasonable reunification efforts; MCL 712A.18f(3)(b) & (c); MCL 712A.19a(2); In re Hicks/Brown; Effect of termination as the DHHS’s goal; MCL 722.638(1)(a)(iii) & (2); In re HRC; Failure to accommodate needs under the American with Disabilities Act (42 USC § 12101 et seq.); Best interests of the children; In re Gonzalez/Martinez; In re Olive/Metts Minors; In re Medina; In re Brown/Kindle/Muhammad Minors; In re White

Holding that the trial court did not err by relying on new evidence, that the DHHS made reasonable reunification efforts, that at least one statutory ground was proven, and that termination was in the children’s best interests, the court affirmed termination of respondents-parents’ parental rights. Their parental rights were terminated based primarily on physical abuse and deplorable living conditions. On appeal, the court rejected respondent-father’s argument that the trial court erred because it terminated his parental rights on the basis of a supplemental petition that contained new allegations, and thus, it could only rely on legally admissible evidence. “Although the trial court relied on the trauma assessments and psychological evaluations, these reports did not constitute evidence of ‘new’ allegations.” Further, “there were no ‘grounds new or different’ that required legally admissible evidence, and the trial court did not” err by relying on the reports. It also rejected his claim that the DHHS failed to make reasonable efforts toward reunification, noting that “[b]ecause continuous, daily physical abuse constituted ‘severe physical abuse’ . . . the DHHS was not required to seek reunification as its goal.” The court next rejected respondent-mother’s contention that the DHHS failed to prove a statutory ground for termination, noting there was a reasonable likelihood that returning the children to her “would result in further physical and psychological damage.” Finally, it rejected her argument that termination was not in the children’s best interests, finding that “a preponderance of the evidence supported the trial court’s decision that termination of” her rights was in their best interests.