Termination under §§ 19b(3)(b)(i), (b)(ii), (b)(iii), (g), (j), & (k)(iii); Reasonable reunification efforts; MCL 712A.19a(2); In re Rippy; Exception for aggravated circumstances; MCL 722.638(1) & (2); Termination at the initial dispositional hearing; MCR 3.977(E); Best interests of the children; In re White

Holding that reasonable reunification efforts were not required, that statutory grounds for termination were met, and that termination was in the children’s best interests, the court affirmed termination of respondents-parents’ parental rights. Their rights were terminated based on medical neglect, physical neglect, improper supervision, and abuse. On appeal, the court rejected respondent-mother’s argument that the DHHS was required to make reasonable reunification efforts before seeking termination, noting the children “were subjected to aggravated circumstances.” It also rejected her claim that the DHHS failed to prove a statutory ground for termination. Given respondent-father’s abuse of one of the children, and history of abuse of another child, her “continued denial of that abuse, and [her] refusal to seek medical treatment after” one child’s (H) injury, the trial court did not err by finding a reasonable likelihood that the children “would suffer injury or abuse in the foreseeable future if placed with” her. The court further rejected her contention that termination was not in the children’s best interests. It noted that her failure to seek proper medical attention for H, and her desire to protect the father from abuse allegations, “outweighed any bond.” It also noted her history of failing to seek proper medical treatment for H and her refusal to accept responsibility or express remorse for the abuse, as well as the fact that she did not have housing, reliable transportation, or employment, and could not provide them with the permanency and stability they needed. Finally, the court rejected the father’s arguments as to statutory grounds and best interests. It found there was clear and convincing evidence that he severely abused H and another child and failed to benefit from prior services. In addition, any bond did not outweigh the evidence of abuse, he failed to accept responsibility or express remorse, he “had a history of domestic violence, had no suitable housing, had transportation issues, and was not employed.”