Termination at an initial disposition; MCL 712A.19b(4); MCR 3.977(E); Reasonable reunification efforts; Aggravated circumstances; MCL 712A.19a(2)(c); Termination under §§ 19b(3)(b)(i) & (j); Child’s best interests; Effect of relative placement; Termination alternatives

The court held that (1) “the trial court appropriately found that reasonable” reunification efforts were not required here pursuant to MCL 712A.19a(2)(c); (2) §§ (b)(i) and (j) were established; and (3) terminating respondent-mother’s parental rights was in the child’s (L) best interests. It determined that “the trial court made clear and detailed findings supporting termination at initial disposition and that additional reasonable efforts were not required pursuant to MCL 712A.19a(2)(c)[.]” Given those findings, it “was not required to make a finding of aggravated circumstances pursuant to MCL 712A.19a(2)(a).” As to statutory grounds for termination, the evidence indicated respondent’s parental rights to L’s “sibling were terminated in 2013 as a result of physical abuse, substance abuse, and failure to complete court-ordered services to rectify the issues.” Evidence also showed that she “failed to rectify her substance abuse at the time of the initial dispositional hearing, and substance abuse was an ongoing and unrectified issue throughout her previous termination case. The trial court” concluded the evidence supported termination under § (j) because respondent’s “continued substance abuse, unemployment, and unstable housing created a reasonable likelihood that” L would be harmed if returned to her care. As to L’s best interests, it “explicitly found that there was a very weak bond between” L and respondent because L did not engage with her “during parenting time, did not ask or talk about [her] after [she] stopped attending parenting times, and no longer ‘had a reaction to not seeing her mother.’ Regardless, the trial court should consider a wide variety of factors and weigh all of the available evidence.” This included that respondent “had battled substance abuse for over a decade, continued to abuse substances despite attending a multitude of rehabilitation programs and being provided with services by DHHS, and did not have stable housing or employment.” The trial court also explicitly considered L’s relative placement. Given respondent’s “substance abuse issues and the prior termination of her” rights to L’s “sibling for the same issues, [L’s] young age and need for permanency and stability, the fact that [L] was thriving in her relative foster placement, and” her placement’s preference for adoption, there was no clear error in the trial court’s finding that termination was in L’s best interests. Affirmed.