The Michigan Supreme Court held that the Department of Health and Human Services (DHHS) was not required to make reasonable efforts to reunify the family because the respondent-parent subjected the child to aggravated circumstances, as defined under MCL 722.638(1) and (2), by facilitating criminal sexual conduct involving penetration, even though the parent did not personally commit the act.

The trial court in this child-protective proceeding correctly placed the mother’s children under its jurisdiction because “some efforts” were made by DHHS to prevent removal of the children.

The MI SCT is considering whether to hear the case of a mother whose parental rights were terminated after the trial court agreed with the petitioning agency that she had subjected her children to “aggravated circumstances”.

The COA vacated a trial court’s order terminating the parental rights of a cognitively impaired young woman due to the repeated failure of DHHS.