Reasonable reunification efforts; MCL 712A.19a(9); Americans with Disabilities Act (ADA); Guardianship; Child’s best interests

The court concluded the “DHHS made reasonable efforts toward the goal of reunification and that reasonable accommodations were offered in compliance with” the DHHS’s responsibilities under MCL 712A.19a(2) and the ADA. Also, it held that neither “of the conditions precedent for establishing a guardianship under MCL 712A.19a(9) was met here, and the trial court” properly found that the termination of respondent-grandfather’s parental rights was in DC’s best interests. The grandfather “and his wife, who is now deceased, legally adopted DC after DC’s biological mother’s parental rights were terminated.” The court held that based on the testimony provided at the hearing, it appeared that the “DHHS was aware that grandfather had cognitive issues that caused memory loss. Along with providing a broad range of services to grandfather, [the DHHS] clearly attempted to provide accommodations for his cognitive and memory issues by providing him with telephone reminders, transportation to and from meetings, and printed calendars to help him remember important dates.” The court concluded that the grandfather had “not identified any specific services that would have better served to accommodate his cognitive issues, nor [did] he explain why the services provided were insufficient or inappropriate.” Affirmed.