Michigan Supreme Court

In Re barber/espinoza Minors

July 31, 2025

Summary

The Court held that a parent subjects a child to aggravated circumstances when the parent sexually exploits the child through facilitating penetrative criminal sexual conduct, even if the parent did not personally commit the sexual act. Because the statutory requirements for aggravated circumstances were met, DHHS was not required to make reasonable reunification efforts, and termination at the initial disposition was authorized. The Court also held that the trial court plainly erred by failing to advise respondent of her right to appeal the removal order, but the error did not affect her substantial rights.