The trial court’s finding that the termination of the respondents’ parental rights was in the child’s best interests must be “conditionally reverse[d],” the Michigan Court of Appeals has ruled, because the Department of Health and Human Services (DHHS) failed to comply with its statutory duty to investigate relative placements.

A father in a TPR case was denied effective assistance of counsel. The Michigan COA vacated the order of termination and remanded the case for further proceedings.