Termination under § 19b(3)(c)(i); In re Williams; Reasonable reunification efforts; Timely raising an alleged violation of the Americans with Disabilities Act (ADA) (42 USC § 12101 et seq.); In re Terry; Tailoring services to accommodate a parent’s special needs; In re Hicks/Brown; Reasonable time to make changes & benefit from services; In re Mason; A parent’s responsibility to participate in services; In re Frey; Child’s best interests; MCL 712A.19b(5); MCR 3.977(E)(4); In re Moss Minors; In re Olive/Metts Minors; In re White; In re VanDalen; Parent-agency treatment plan (PATP)

The court concluded that the DHHS provided respondent-mother with suitable accommodations and several opportunities to engage in services that could have helped her, but “she refused to cooperate and failed to benefit from” them. Thus, it rejected her claim that the DHHS did not make reasonable reunification efforts. It also held that § (c)(i) supported termination, and that terminating her parental rights was in the child’s best interests. Noting that the issue of whether the DHHS violated the ADA was unpreserved, the court found that the record showed the DHHS acknowledged during the case that she “had intellectual impairments despite respondent’s denial of any mental health issues.” The record also supported the trial court’s finding that the DHHS provided reunification services, including, among others, individual counseling, funding for counseling, parent mentoring, “a substance abuse assessment, two psychological evaluations, housing assistance, transportation assistance,” and parenting time. It also provided “reasonable modifications to accommodate her impairments, including reading and explaining the” PATP to her, providing her with a brief summary of the PATP, explaining the relevant dates and expectations to her, discussing the PATP “with her social worker and her attorney, requesting a female counselor for” her, and extending her parent-mentor services. But the evidence showed that she “failed to avail herself of the services and reasonable accommodations made for her impairments.” As to § (c)(i), the evidence established that she failed to make “the necessary life changes to enable her to provide proper care and custody of the child. Although respondent obtained housing, she failed to participate in services to enable her to overcome her mental health issues and she failed to develop parenting skills to permit reunification with the child.” It had been over 182 days since the initial disposition and the conditions leading to adjudication still existed, with no reasonable likelihood they “would be rectified within a reasonable time considering the child’s age.” As to the child’s best interests, “evidence established that respondent’s conduct negatively impacted” her and that she had developed a bond with her foster family, who were interested in adopting her. Affirmed.