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February 03, 2022

Michigan

DEPENDENCY

DISPOSITIONAL ORDER

In re Sanders, 852 N.W.2d 524 (Mich. 2014). Where child was removed from mother, and petition was dismissed against father, trial court erred in continuing to dispositional hearing. Because parents are presumed fit, prior case law allowing dispositions against nonoffending parents based on adjudication of offending parent violated procedural due process. Full Summary

TERMINATION OF PARENTAL RIGHTS

REASONABLE EFFORTS

In re Hicks/Brown, 893 N.W.2d 637 (Mich. 2017). The Michigan Supreme Court found a child welfare agency’s required reunification efforts were not reasonable unless the agency modified services, as reasonably necessary, to accommodate parent’s disability. Court ruled termination of parental rights must have proper finding of reasonable efforts, which had not happened in this case.  FULL SUMMARY