Termination; Reasonable reunification efforts; In re Hicks/Brown; Exception for aggravating circumstances; MCL 712A.19a(2); MCL 722.638; In re Mason; “Child abuse”; MCL 722.622(g); Best interests of the children; MCL 712A.19b(5); In re White

The court held that the trial court erred by finding the DHHS was relieved of its obligation to provide reunification efforts as to respondent-mother, but did not err by finding the trial court was relived of this duty as to respondent-father (who was the father to one of the children). It also held that the trial court did not err in finding termination of the father’s parental rights was in his child’s best interests. The mother’s parental rights to the children were terminated on the basis of untreated mental illness, hospitalizations, and improper supervision, while the father’s rights to his child were terminated on the basis of child abuse and abandonment. On appeal, they both argued that the trial court erred by finding reasonable efforts were not required. The court determined the trial court erred by finding the DHHS was relieved of its obligations to provide reasonable efforts as to the mother because untreated mental illness, hospitalizations, and improper supervision are circumstances “not contemplated by MCL 712A.19a(2) or MCL 722.638.” As to the father, however, the trial court did not err because he abandoned the child years earlier. The court also rejected the father’s claim that termination was not in the child’s best interests, finding the trial court “properly weighed the appropriate factors when considering [the child’s] best interests, and on balance, a preponderance of the evidence weighed in favor of terminating [his] parental rights.” Affirmed as to the father, reversed and remanded as to the mother.