COA 377671 IN RE D E JONES MINOR Opinion - Per Curiam - Unpublished 6/22/2026

377671Court Of Appeals22 de jun. de 2026

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If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
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S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
UNPUBLISHED
June 22, 2026
1:59 PM
In re JONES/AUSTIN, Minors.
Nos. 377671; 377673; 377674;
377675; 377677
Calhoun Circuit Court
Family Division
LC No. 2021-002425-NA
Before: GADOLA, C.J., and RIORDAN and LETICA, JJ.
PER CURIAM.
In these consolidated cases,1 the trial court terminated respondent-mother’s parental rights
to DJ, M1, M2, and M3,2 and respondent-father’s parental rights to M1, M2, and M3. On appeal,
respondent-mother argues that the Department of Health and Human Services (DHHS) failed to
make accommodations for her intellectual disability, that the trial court erred by terminating her
rights under MCL 712A.19b(3)(c)(i) and (j), and that termination was not in the children’s best
interests. Respondent-father argues that the trial court abused its discretion by not allowing a
rebuttal witness to testify, that termination was not in the children’s best interests, and that the trial
court erred by terminating his parental rights to M3 at initial disposition. We affirm.
I. BACKGROUND
In August 2021, 16-month-old DJ went to the hospital after ingesting methamphetamine in
respondents’ home. At the hospital, DJ, who also had hip dysplasia and developmental delays,
tested positive for amphetamines and had scabies. Further, there were concerns of ongoing
domestic violence in the home, and respondent-mother had pending charges of first-degree
criminal sexual conduct (CSC) related to allegations that she sexually assaulted her younger
1 In re Jones/Austin, unpublished order of the Court of Appeals, entered October 21, 2025 (Docket
Nos. 377671, 377673, 377674, 377675, and 377675).
2 The trial court also terminated the parental rights of DJ’s father, but he is not a party to this
appeal.

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cousins when she was a teenager. The trial court removed DJ from respondent-mother and his
father.
Respondent-father was arrested in April 2022 after assaulting respondent-mother, which
caused her to be hospitalized. Respondent-mother gave birth to M1 and M2 in July 2022, and the
trial court removed them from respondents. Respondent-mother was, by that point, on probation
after pleading guilty in her CSC case. Respondents also both pleaded guilty to child-abuse charges
related to DJ’s injuries.
A November 2022 psychological evaluation indicated that respondent-mother had an
intellectual disability, after which the DHHS agreed that it needed to provide accommodations to
her under Hicks/Brown.3 Respondent-mother was incarcerated in June 2023 and again in August
2023 until April 2024 for violating a no-contact order with respondent-father. The DHHS filed a
termination petition in February 2024. After the foster-care agency repeatedly failed to timely file
reports, however, the trial court dismissed the termination petition and dismissed the agency from
the case in April 2024. Accordingly, a DHHS caseworker assumed responsibility for the case.
Respondents took some parenting classes, and respondent-father became employed at the
Women’s Co-op. Respondents also obtained housing. Respondents, however, missed most of
their drug screens and, for most of the case, failed to participate in counseling services at Summit
Point or domestic-violence services at Wings of a Dove as instructed. Respondents did not want
to engage at Wings of a Dove because they could not participate together. Instead, respondents
began counseling at the Women’s Co-op with an unlicensed student therapist. The DHHS
expressed concern about the conflict of respondent-father working at the Women’s Co-op and
ultimately learned that respondent-father was distantly related to certain staff at the Women’s Co-
op.
The DHHS filed a new termination petition in October 2024, and a termination trial began
in December 2024. Respondent-mother gave birth to M3 in May 2025, at which point the trial
court removed him from respondents’ care, and the DHHS requested that the trial court terminate
respondents’ parental rights to M3. On September 3, 2025, the trial court terminated respondent-
mother’s parental rights to DJ, M1, and M2, as well as respondent-father’s parental rights to M1
and M2. The trial court took additional testimony regarding M3 on that day and the following
day. Respondent-father’s attorney attempted to have respondents’ counselor from the Women’s
Co-op, Kimberly Danke, testify in rebuttal. Respondent-father had not included Danke on any
witness lists. After arguments by the parties, the trial court ordered that Danke could testify
narrowly about her credentials and in rebuttal to testimony given. Before the lawyer-guardian
ad litem could cross-examine Danke, however, Danke disconnected from the hearing, and the trial
court struck her testimony. The trial court then terminated respondents’ parental rights to M3.
Respondents now appeal.
3 In re Hicks/Brown, 500 Mich 79; 893 NW2d 637 (2017).

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II. RESPONDENT-FATHER’S APPEAL
A. REBUTTAL
First, respondent-father argues that the trial court abused its discretion by denying him the
right to present a rebuttal lay witness in the proceedings involving M3.
As the prosecution argues on appeal, however, this issue is moot because the trial court
struck Danke’s testimony after she disconnected from the hearing but before Danke completed
cross-examination. This Court will not decide moot issues. In re Smith, 355 Mich App 514, 519;
967 NW2d 857 (2021). An issue is moot if an event occurs that renders it impossible for this Court
to grant relief. CD Barnes Assoc, Inc v Star Heaven, LLC, 300 Mich App 389, 406; 834 NW2d
878 (2013). In other words, because the trial court did initially allow Danke to testify, and because
respondent-father does not challenge its subsequent decision to strike her testimony, there is no
relief that we may afford with regard to this issue.
Respondent-father argues that Danke would not have become disconnected had the trial
court “simply let [Danke] testify as to her impressions based on her rational perception.” A trial
court must, however, determine preliminary questions about factors like a witness’s qualification
or the admissibility of evidence. See MRE 104(a). Thus, the trial court did not err by first
addressing whether Danke could appropriately testify in rebuttal, and with what scope, particularly
when the prosecution and the lawyer-guardian ad litem objected to her testimony. When the trial
court struck Danke’s testimony, however, the issue of the admissibility of that testimony became
moot.
B. TERMINATION AT INITIAL DISPOSITION
Next, respondent-father argues that the trial court erred by terminating his parental rights
to M3 at initial disposition.
We review for clear error a trial court’s factual findings and determination that a statutory
ground for termination has been satisfied. In re White, 303 Mich App 701, 709; 846 NW2d 61
(2014). Clear error exists if this Court is left with a definite and firm conviction that the trial court
made a mistake, “giving due regard to the trial court’s special opportunity to observe the
witnesses.” In re BZ, 264 Mich App 286, 296-297; 690 NW2d 505 (2004).
Generally, when a child is removed from a parent, the DHHS is required to make
reasonable efforts to rectify the conditions that led to the removal. In re Fried, 266 Mich App 535,
542; 702 NW2d 192 (2005). Reasonable efforts are not required, however, if, among other
possible conditions, there was “a judicial determination that the parent has subjected the children
to aggravated circumstances as provided in section 18(1) and (2) of the child protection law, 1975
PA 238, MCL 722.638,” MCL 712A.19a(2)(a); “[t]he parent has had rights to the child’s siblings
involuntarily terminated and the parent has failed to rectify the conditions that led to that
termination of parental rights,” MCL 712A.19a(2)(c); or “[t]he parent is required by court order
to register under the sex offenders registration act,” MCL 712A.19a(2)(d). See also In re Moss,
301 Mich App 76, 90-91; 836 NW2d 182 (2013). MCL 712A.19a(2) “substantively incorporates
MCL 722.638, setting the parameters for when the trial court may excuse reasonable efforts aimed
at reunification if the aggravated circumstances outlined in MCL 722.638(1) and (2) exist.” In re

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Barber/Espinoza, ___ Mich ___, ___ n 5; ___ NW3d ___ (2025) (Docket No. 167745), slip op
at 9 n 5. When the DHHS has filed a petition to terminate the parental rights of a child, the trial
“court may enter an order terminating parental rights under subsection (3) at the initial
dispositional hearing.” MCL 712A.19b(4).
In this case, after the preliminary hearing, the trial court properly determined that
reasonable efforts were not required for respondent-father because of his previous termination of
rights to his other child and his failure to rectify the conditions that led to that termination. See
MCL 712A.19a(2)(c). In September 2025, the trial court heard two days of testimony before
terminating respondent-father’s parental rights to M3. Thus, the trial court did not err by
considering the DHHS’s request for termination at initial disposition.
To terminate parental rights, the trial court must find clear and convincing evidence of at
least one statutory basis for termination under MCL 712A.19b(3). See In re Sanborn, 337 Mich
App 252, 272; 976 NW2d 44 (2021). A ground for termination exists under MCL 712A.19b(3)(i)
if “[p]arental rights to 1 or more siblings of the child have been terminated due to serious and
chronic neglect or physical or sexual abuse, and the parent has failed to rectify the conditions that
led to the prior termination of parental rights.” MCL 712A.19b(3)(i) is an appropriate ground for
termination at initial disposition when the circumstances warrant it. See MCR 3.977(E)(3)(b).
By the time the trial court terminated respondent-father’s parental rights to M3 on
September 4, 2025, the trial court had terminated his parental rights to M1 and M2 on September 3,
2025, and to his other child in 2023. Accordingly, the trial court did not err by finding that
respondent-father’s parental rights to one or more of M3’s siblings already had been terminated.
See MCL 712A.19b(3)(i). Respondent-father had shown progress related to housing and
employment, and he had not had any positive methamphetamine screens, but he had a history of
failing to engage in services, particularly to address domestic violence and substance abuse.
Respondent-father tested positive for cocaine in July 2025, and substance abuse was a significant
concern considering the serious injury that DJ suffered from methamphetamine ingestion in
respondents’ home. Further, respondent-father had purportedly stabbed respondent-mother while
she was pregnant with M1 and M2, although respondents denied this at trial; regardless,
respondent-father failed to even begin addressing the domestic-violence concerns until July 2025.
Respondent-father continued to demonstrate emotional dysregulation during hearings. The trial
court noted that respondent-father had not, apparently, addressed his anger issues. Accordingly,
the trial court did not clearly err by finding that respondent-father’s parental rights had been
terminated to M3’s siblings under circumstances that may be characterized as “serious and chronic
neglect or physical or sexual abuse,” and that he had failed to rectify the conditions that led to
those terminations. See MCL 712A.19b(3)(i).
Moreover, a ground for termination exists under MCL 712A.19b(3)(j) if “[t]here is a
reasonable likelihood, based on the conduct or capacity of the child’s parent, that the child will be
harmed if he or she is returned to the home of the parent.” “[A] parent’s failure to comply with
the terms and conditions of his or her service is evidence that the child will be harmed if returned
to the parent’s home.” In re White, 303 Mich App at 711.
The trial court did not clearly err by finding that termination was warranted under this
ground, for many of the same reasons as earlier noted. Respondent-father had a significant history

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of substance abuse and domestic violence. Although respondent-father had obtained employment
and housing, there is no indication that he had addressed his anger issues. The trial court found
that aggravated circumstances existed, so the DHHS did not offer services in M3’s case, but
respondent-father demonstrated inconsistent compliance throughout the years of offered services.
DJ suffered serious injuries when he ingested methamphetamine while in respondents’ care, and
respondent-father tested positive for cocaine in July 2025. By the time of the termination
proceedings related to M1 and M2, respondent-father had not engaged in mental-health services
and had stopped taking his prescribed medication. Moreover, he repeatedly walked out of hearings
when he was upset. Accordingly, the trial court did not clearly err by finding that there was a
reasonable risk of harm to M3 if he was returned to respondent-father’s care. See MCL
712A.19b(3)(j).
C. BEST INTERESTS
Finally, respondent-father argues that the trial court erred by finding that termination was
in the children’s best interests.
“Even if the trial court finds that the Department has established a ground for termination
by clear and convincing evidence, it cannot terminate the parent’s parental rights unless it also
finds by a preponderance of the evidence that termination is in the best interests of the children.”
In re Gonzales/Martinez, 310 Mich App 426, 434; 871 NW2d 868 (2015). We review for clear
error a trial court’s best-interest determination. In re Sanborn, 337 Mich App at 276.
When determining whether termination is in a child’s best interests, the trial court may
consider evidence that includes “the child’s bond to the parent, the parent’s parenting ability, the
child’s need for permanency, stability, and finality, and the advantages of a foster home over the
parent’s home.” In re Atchley, 341 Mich App 332, 346; 990 NW2d 685 (2022) (quotation marks
and citation omitted). Further, the trial court may consider “the length of time the child was in
care, the likelihood that the child could be returned to her parents’ home within the foreseeable
future, if at all, and compliance with the case service plan.” Id. at 346-347 (quotation marks and
citation omitted). The focus of the best-interest determination is on the child, rather than the
parent. Id. at 346.
In this case, the trial court properly considered the children’s best interests. M1 and M2
were together in a preadoptive placement, along with DJ and M3, and they were doing well in the
home. Respondent-father argues on appeal that the trial court failed to specifically address M1’s
and M2’s best interests as they related to respondent-father. In its best-interest determination,
however, the trial court specifically noted concerns with respondent-father’s behavior and
emotional stability. The trial court’s best-interest explanation was brief, but, during the statutory-
grounds determination, the trial court considered factors such as respondent-father’s criminality,
violence, substance abuse, and his refusal to engage in services.
By the time of the termination decision, respondents had only just begun services at Wings
of a Dove and had refused participation at Summit Point and Grace Health for most of the case.
Moreover, M1 and M2 had never lived with respondents. Although respondents had obtained
housing, respondent-father was employed, and respondents had been consistent with parenting
time and, over the previous few months, with drug screens, respondents were, overall, not

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compliant with the majority of their services throughout the case. See id. at 346-347. There
remained significant domestic-violence concerns, including that respondent-father purportedly
stabbed respondent-mother while she was pregnant with M1 and M2, although respondents denied
that at trial, as well as respondent-father’s 2024 conviction of domestic violence against another
woman. Further, respondent-father tested positive for cocaine in July 2025. Although he disputed
that result, these cases began because DJ ingested methamphetamine while in the care of
respondents. Accordingly, substances remained a concern nearly four years later. The trial court
did not fail to consider respondent-father when determining the twins’ best interests and did not
clearly err by finding that termination was in M1’s and M2’s best interests. See In re
Gonzales/Martinez, 310 Mich App at 434.
Next, the trial court did not clearly err by finding that terminating respondent-father’s
parental rights was in M3’s best interests as well. Although respondent-father argues on appeal
that the trial court should have allowed more time before making the determination, the trial court
had nearly four years of respondent-father’s history to consider. Not only had the trial court just
terminated respondent-fathers’ parental rights to M1 and M2 the day before, the trial court
previously terminated his parental rights to his other child in 2023. In this case, the trial court
considered that M3 was in a preadoptive placement with DJ, M1, and M2, and the trial court found
that respondent-father could not, considering his history, rectify his issues in a reasonable time.
The trial court also acknowledged that respondent-father loved M3 and his siblings. Considering,
however, the serious domestic violence and substance concerns in the home for several years, the
length of time that M3’s siblings had been out of the home, and respondent-father’s ongoing
inconsistency with services when M3 required permanency, the trial court did not clearly err by
finding that termination of respondent-father’s rights was in M3’s best interests.
III. RESPONDENT-MOTHER’S APPEAL
A. ACCOMMODATIONS
First, respondent-mother argues that the DHHS failed to make accommodations when
offering services.
We review for clear error whether the DHHS made reasonable efforts to preserve and
reunify the family. See In re MJC, 349 Mich App 42, 47; 27 NW3d 122 (2023). Further, we
review de novo as a question of constitutional law whether a child-protective proceeding afforded
a parent due process. In re Rood, 483 Mich 73, 91; 763 NW2d 587 (2009).
Under the Americans with Disabilities Act, 42 USC 12101 et seq., the DHHS must make
reasonable accommodations for respondents with disabilities. See In re Hicks/Brown, 500 Mich
79, 86; 893 NW2d 637 (2017). If the DHHS failed to make such accommodations, then efforts at
reunification are not reasonable. Id. Termination is improper without a trial court finding of
reasonable efforts. Id. at 90.
In this case, the trial court did not clearly err by determining that the DHHS made
reasonable efforts and accommodations toward respondent-mother’s reunification with DJ, M1,
and M2. Although respondent-mother argues that she testified “without contradiction” that the
DHHS rarely used the Teach-Back method, DHHS caseworker Erin Geier testified that she had

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respondent-mother explain the service plans back to Geier in respondent-mother’s own words and
carefully reviewed the parent-agency treatment plans with her. Further, Geier twice created
specific checklists for respondent-mother, explaining the required services. Although Geier also
made the checklists for respondent-father, Geier’s extra efforts for respondent-father do not detract
from the efforts for respondent-mother, particularly when respondents operated as one household,
and respondent-father’s engagement in services affected respondent-mother’s reunification
efforts.
The only service that respondent-mother identified at trial that would have been helpful to
her were services to help her with DJ’s special needs. The DHHS had, however, twice referred
respondent-mother to supportive visitation, but respondent-mother did not participate.
Respondent-mother completed some counseling and other services before she was incarcerated, as
well as at least some parenting education. Had respondent-mother completed her second
psychological evaluation, however, or consistent counseling once Geier became involved in the
case, respondent-mother may have obtained those added supports. Although respondent-mother
argues that she did not understand until April 2025 that the service “recommendations” were court
orders because nobody explained that to her, the trial court specifically rejected that claim. When
Geier repeatedly reviewed the services with respondent-mother, respondent-mother was present
for hearings at which the parties discussed the services, and the trial court ordered that respondent-
mother comply with the service plans, the trial court’s findings were not clearly erroneous.
Respondent-mother also argues that she was not granted parenting time during her
incarceration. Although there was some testimony that respondent-mother used her free video
calls to speak with others, rather than her children, caseworkers from Samaritas testified about
facilitating weekly video visits while respondent-mother was in jail. Limiting respondent-mother
to parenting time only if she had a free call available would be unreasonable, particularly under
the circumstances of respondent-mother’s cognitive disabilities and domestic violence.
Regardless, the trial court removed Samaritas from the case because of its failures to communicate
and file required documents. At that point, the trial court also dismissed the pending termination
petition, which gave respondent-mother a continued opportunity to work toward reunification.
Geier and the DHHS indisputably made parenting time available to respondent-mother. Therefore,
the trial court did not err by finding that the DHHS made reasonable efforts and accommodations
for respondent-mother.
B. STATUTORY GROUNDS
Next, respondent-mother argues that the trial court erred by finding that statutory grounds
for termination existed under MCL 712A.19b(3)(c)(i) and (j).
MCL 712A.19b(3)(c)(i) and (j) were the grounds under which the trial court terminated
respondent-mother’s parental rights to M1, M2, and DJ. The trial court, however, terminated
respondent-mother’s parental rights of M3 under MCL 712A.19b(3)(i), (j), and (k). A trial court
need only find one statutory ground to terminate a parent’s rights, even if the trial court errs by
finding sufficient evidence under another statutory ground. See In re Ellis, 294 Mich App 30, 32;
817 NW2d 111 (2011). Because respondent-mother fails to address two statutory grounds that
resulted in termination of her rights to M3, respondent-mother abandoned her statutory-ground

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challenge of M3, and this Court need not review it. See In re Rippy, 330 Mich App 350, 362 n 5;
948 NW2d 131 (2019).
Next, as to the other three children under MCL 712A.19b(3)(c)(i), the trial court issued its
disposition order as to respondent-mother and DJ on November 8, 2021, which was significantly
more than 182 days before the trial court issued its termination order on September 3, 2025. See
MCL 712A.19b(3)(c)(i).4 The trial court issued its dispositional order as to respondent-mother
and the twins on August 31, 2022, which also was significantly more than 182 days before the trial
court terminated respondent-mother’s parental rights to M1 and M2 on September 3, 2025.
Further, the trial court did not clearly err by finding that the conditions that led to the
adjudication continued to exist. See id. With DJ, respondent-mother pleaded to issues including
substance abuse in the home, pending CSC charges, the need for services, and her inability to
provide a safe home or proper care and custody of DJ. In regard to M1 and M2, respondent-mother
pleaded to issues involving housing; an inability to provide proper care and custody; the need for
services to address mental-health, substance-abuse, and domestic-violence issues; and her CSC
probation. By the time that the trial court terminated respondent-mother’s parental rights to DJ,
M1, and M2, respondent-mother had engaged in minimal services and failed to demonstrate
significant benefit, although respondent-mother had obtained housing and had income.
Respondent-mother previously had housing, however, and lost it for twice violating a no-contact
order with respondent-father. Although respondent-mother reportedly could not maintain her
current home without the assistance of respondent-father, there were significant concerns about
domestic violence between the two, which respondent-mother failed to address throughout the
case.
Moreover, the case began when DJ ingested methamphetamine in respondents’ home.
Respondent-mother was inconsistent with drug screens throughout the case until the last few
months of the termination proceedings. Generally, the only positive screens were for
tetrahydrocannabinol (THC), to which, other than while respondent-mother was pregnant, the
DHHS did not object. Geier confirmed, however, that she informed respondents that missed
screens were considered to be positive screens. Further, respondent-father tested positive for
cocaine in July 2025, well into the termination proceedings. Respondents were acting as a single
household, so respondent-father’s use of an illegal substance meant that respondent-mother was
not in a substance-free home. Considering the limited participation in services and progress, the
trial court did not clearly err by finding that respondent-mother would not rectify the conditions
that led to adjudication in a reasonable time. See id.
Further, while we need not address the issue, for many of the same reasons as with
MCL 712A.19b(3)(c)(i), the trial court did not clearly err by finding that termination of
respondent-mother’s parental rights was warranted under MCL 712A.19b(3)(j). Domestic
4 MCL 712A.19b(3)(c)(i) provides that termination is appropriate when “[t]he parent was a
respondent in a proceeding brought under this chapter, 182 or more days have elapsed since the
issuance of an initial dispositional order, and the court, by clear and convincing evidence, finds . . .
[t]he conditions that led to the adjudication continue to exist and there is no reasonable likelihood
that the conditions will be rectified within a reasonable time considering the child’s age.”

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violence was a significant concern for respondents. Respondent-mother admitted to being the
victim and a perpetrator of violence. Significantly, respondent-mother’s grandmother testified that
respondent-father stabbed respondent-mother while she was pregnant with the twins. Respondent-
mother denied at trial that respondent-father stabbed her in that incident, but she admitted that he
was violent with her and that she did not fight back on that occasion. Moreover, respondent-father
had been convicted of domestic violence against another woman in January 2024.
It would not be proper for this Court to hold against a person that he or she was the victim
of domestic violence. See In re Plump, 294 Mich App 270, 273; 817 NW2d 119 (2011). However,
a parent’s own actions that harm his or her children, or expose them to harm, or an inability to
protect his or her child, are important considerations. See id. Respondent-mother had only started
to address domestic violence at Wings of a Dove in July 2025, nearly four years into the beginning
of her involvement with the DHHS, and respondent-mother also did not think that that service was
sufficient because Wings of a Dove solely treated her as a victim while she had also been violent
with respondent-father. Whether respondent-mother acted violently to defend herself or for some
other reason, respondent-mother had chosen not to engage with Wings of a Dove in 2024 because
she could not participate with respondent-father. Respondent-father also was the payee for
respondent-mother’s SSI benefits, which raised concerns about his influence over her. Members
of respondent-mother’s family had stopped supporting her because of her relationship with
respondent-father, and Geier had been concerned that respondent-father drove a wedge between
respondent-mother and the previously supportive foster parent, in addition to respondent-father
speaking for respondent-mother during meetings.
Respondent-mother also testified that DJ’s father raped her, resulting in her pregnancy with
DJ. Despite the sexual assault, respondent-mother allowed DJ’s father to have parenting time with
DJ, purportedly at the behest of respondent-mother’s family. Moreover, respondent-mother’s
mother lived with DJ’s father, and respondent-mother testified that her mother used
methamphetamine. And, in respondent-mother’s own home, regardless of whether it was
respondent-father or both respondents using methamphetamine, DJ ingested methamphetamine.
Further, despite making progress earlier in the case, respondent-mother at least twice violated her
no-contact order with respondent-father and ended up incarcerated for a significant period. Her
incarceration, although not a sole reason to terminate parental rights, see In re Mason, 486 Mich
142, 160; 782 NW2d 747 (2010), caused her to lose her housing and impeded her efforts overall.
Therefore, the trial court did not clearly err by terminating respondent-mother’s parental rights
under MCL 712A.19b(3)(j).
C. BEST INTERESTS
Finally, respondent-mother argues that the trial court erred by finding that termination was
in the children’s best interests.
The record demonstrated that respondent-mother’s parenting time generally went well.
Although respondent-mother argues that the DHHS downplayed her bond with the children, Geier
testified that her observations were that DJ, M1, and M2 were happy to see respondents, but they
were more excited to see their foster parents than they were to see respondents. Geier also testified
that M3 acted similarly whether with his foster parents or respondents. Geier, accordingly, did not
deny that the children, especially the older three, had positive relationships with respondent-

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mother. Specifically during termination proceedings for M3, the trial court also noted that
respondents loved the children. Accordingly, the trial court did not clearly err when considering
the bonds that the children shared with respondent-mother. See In re Atchley, 341 Mich App
at 346.
The trial court also did not clearly err by finding that the children needed permanency. See
id. DJ, M1, and M2 had been in foster care for years. Only in July 2025, months into the
termination proceedings, did respondents begin to engage in domestic-violence services. That
same month, respondent-father tested positive for cocaine, and respondents were operating as a
single household. Accordingly, substance abuse remained a concern in the household.
Respondent-mother had a responsibility to participate in, and benefit from, services, and the record
demonstrated limited compliance or benefit. See In re Frey, 297 Mich App 242, 247-248; 824
NW2d 569 (2012). It was unlikely that the children would be able to return to respondents’ care.
The trial court also found that the children were placed in a preadoptive home together.
Although respondent-mother argues on appeal that the trial court failed to consider less-drastic
measures, Geier did not think that the foster parents were interested in a guardianship.
Respondent-mother also argues that Geier testified that reunification could occur in three to six
months, or sooner if respondent-mother parented alone, but Geier testified that reunification in that
period only was possible if respondents demonstrated sobriety and compliance with services. The
record demonstrated that respondent-mother had come close to reunification earlier in the case but
was then incarcerated for twice violating a no-contact order with respondent-father. Accordingly,
although respondent-mother had been more compliant with services in the last couple months
before termination, respondent-mother did not demonstrate that she could maintain that
compliance or benefit in the long term. Moreover, respondent-mother intended to remain with
respondent-father, so her chances of reunification also relied on respondent-father’s compliance,
and he had just tested positive for cocaine and stopped his medication without medical guidance.
Finally, although respondent-mother argues on appeal that the trial court could not assume
that adoption was superior to reunification or would provide greater stability, the trial court made
its best-interest determination on the basis of its understanding of the years-long cases. Therefore,
the trial court did not clearly err by finding that termination of respondent-mother’s parental rights
was in the children’s best interests.
IV. CONCLUSION
There were no errors warranting relief in any of the consolidated cases before us.
Accordingly, we affirm.
/s/ Michael F. Gadola
/s/ Michael J. Riordan
/s/ Anica Letica

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