Michigan Compiled Laws

Mich. Comp. Laws § 712A.19 (2026)

Termination of cause; supplemental order of disposition; review hearing; notice of review hearing; factors to be reviewed; modification of case service plan; determination as to placement; order; determination as to review; issuance of order without hearing; agency report and other information as evidence; access; concurrent efforts to reunify child with family.

✓ current as of July 2026
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PROBATE CODE OF 1939


Act 288 of 1939


712A.19 Termination of cause; supplemental order of disposition; review hearing; notice of review hearing; factors to be reviewed; modification of case service plan; determination as to placement; order; determination as to review; issuance of order without hearing; agency report and other information as evidence; access; concurrent efforts to reunify child with family.

Sec. 19.

    (1) Subject to section 20 of this chapter, if a child remains under the court's jurisdiction, a cause may be terminated or an order may be amended or supplemented, within the authority granted to the court in section 18 of this chapter, at any time as the court considers necessary and proper. An amended or supplemented order must be referred to as a "supplemental order of disposition". If the agency becomes aware of additional abuse or neglect of a child who is under the court's jurisdiction and if that abuse or neglect is substantiated as provided in the child protection law, 1975 PA 238, MCL 722.621 to 722.638, the agency shall file a supplemental petition with the court.

    (2) Except as provided in subsections (3) and (4), if a child subject to the court's jurisdiction remains in his or her home, a review hearing must be held not more than 182 days from the date a petition is filed to give the court jurisdiction over the child and no later than every 91 days after that for the first year that the child is subject to the court's jurisdiction. After the first year that the child is subject to the court's jurisdiction, a review hearing shall be held no later than 182 days from the immediately preceding review hearing before the end of that first year and no later than every 182 days from each preceding review hearing after that until the case is dismissed. A review hearing under this subsection must not be canceled or delayed beyond the number of days required in this subsection, regardless of whether a petition to terminate parental rights or another matter is pending. Upon motion by any party or in the court's discretion, a review hearing may be accelerated to review any element of the case service plan prepared according to section 18f of this chapter.

    (3) Except as otherwise provided in subsection (4), if, in a proceeding under section 2(b) of this chapter, a child is subject to the court's jurisdiction and removed from his or her home, a review hearing must be held not more than 182 days after the child's removal from his or her home and no later than every 91 days after that for the first year that the child is subject to the court's jurisdiction. After the first year that the child has been removed from his or her home and is subject to the court's jurisdiction, a review hearing must be held not more than 182 days from the immediately preceding review hearing before the end of that first year and no later than every 182 days from each preceding review hearing after that until the case is dismissed. A review hearing under this subsection must not be canceled or delayed beyond the number of days required in this subsection, regardless of whether a petition to terminate parental rights or another matter is pending. Upon motion by any party or in the court's discretion, a review hearing may be accelerated to review any element of the case service plan prepared according to section 18f of this chapter.

    (4) If a child is under the care and supervision of the agency and is either placed with a relative and the placement is intended to be permanent or is in a permanent foster family agreement, the court shall hold a review hearing not more than 182 days after the child has been removed from his or her home and no later than every 182 days after that so long as the child is subject to the jurisdiction of the court, the Michigan children's institute, or other agency. A review hearing under this subsection must not be canceled or delayed beyond the number of days required in this subsection, regardless of whether a petition to terminate parental rights or another matter is pending. Upon the motion of any party or at the court's discretion, a review hearing may be accelerated to review any element of the case service plan.

    (5) Written notice of a review hearing under subsection (2), (3), or (4) must be served on all of the following:

    (a) The agency. The agency shall advise the child of the hearing if the child is 11 years of age or older.

    (b) The child's foster parent or custodian.

    (c) If the parental rights to the child have not been terminated, the child's parents.

    (d) If the child has a guardian, the guardian for the child.

    (e) If the child has a guardian ad litem, the guardian ad litem for the child.

    (f) A nonparent adult if the nonparent adult is required to comply with the case service plan.

    (g) If tribal affiliation has been determined, the elected leader of the Indian tribe.

    (h) The attorney for the child, the attorney for each party, and the prosecuting attorney if the prosecuting attorney has appeared in the case.

    (i) If the child is 11 years of age or older, the child.

    (j) Other persons as the court may direct.

    (6) At a review hearing under subsection (2), (3), or (4), the court shall review on the record all of the following:

    (a) Compliance with the case service plan with respect to services provided or offered to the child and the child's parent, guardian, custodian, or nonparent adult if the nonparent adult is required to comply with the case service plan and whether the parent, guardian, custodian, or nonparent adult if the nonparent adult is required to comply with the case service plan has complied with and benefited from those services.

    (b) Compliance with the case service plan with respect to parenting time with the child. If parenting time did not occur or was infrequent, the court shall determine why parenting time did not occur or was infrequent.

    (c) The extent to which the parent complied with each provision of the case service plan, prior court orders, and an agreement between the parent and the agency.

    (d) Likely harm to the child if the child continues to be separated from the child's parent, guardian, or custodian.

    (e) Likely harm to the child if the child is returned to the child's parent, guardian, or custodian.

    (7) After review of the case service plan, the court shall determine the extent of progress made toward alleviating or mitigating the conditions that caused the child to be placed in foster care or that caused the child to remain in foster care. The court may modify any part of the case service plan including, but not limited to, the following:

    (a) Prescribing additional services that are necessary to rectify the conditions that caused the child to be placed in foster care or to remain in foster care.

    (b) Prescribing additional actions to be taken by the parent, guardian, nonparent adult, or custodian, to rectify the conditions that caused the child to be placed in foster care or to remain in foster care.

    (8) At a review hearing under subsection (2), (3), or (4), the court shall determine the continuing necessity and appropriateness of the child's placement and shall order the return of the child to the custody of the parent as provided in this subsection, continue the dispositional order, modify the dispositional order, or enter a new dispositional order. The court shall order the child returned to the custody of his or her parent if returning the child to his or her parent would not cause a substantial risk of harm to the child.

    (9) If in a proceeding under section 2(b) of this chapter a child is placed in foster care, the court shall determine at the dispositional hearing and each review hearing whether the cause should be reviewed before the next review hearing required by subsection (2), (3), or (4). In making this determination, the court shall consider at least all of the following:

    (a) The parent's ability and motivation to make necessary changes to provide a suitable environment for the child.

    (b) Whether there is a reasonable likelihood that the child may be returned to his or her home before the next review hearing required by subsection (2), (3), or (4).

    (10) At a review hearing under this section, the court shall approve or disapprove a qualified residential treatment program placement as provided in section 13a of 1973 PA 116, MCL 722.123a.

    (11) Unless waived, if not less than 7 days' notice is given to all parties before returning a child to the child's home, and no party requests a hearing within the 7 days, the court may issue an order without a hearing permitting the agency to return the child to the child's home.

    (12) An agency report filed with the court must be accessible to all parties to the action and must be offered into evidence. The court shall consider any written or oral information concerning the child from the child's parent, guardian, custodian, foster parent, child caring institution, relative with whom a child is placed, attorney, lawyer-guardian ad litem, or guardian ad litem, in addition to any other evidence, including the appropriateness of parenting time, offered at the hearing.

    (13) Reasonable efforts to finalize an alternate permanency plan may be made concurrently with reasonable efforts to reunify the child with the family.

    (14) Reasonable efforts to place a child for adoption or with a legal guardian, including identifying appropriate in-state or out-of-state options, may be made concurrently with reasonable efforts to reunify the child and family.

    

    

History: Add. 1944, 1st Ex. Sess., Act 54, Imd. Eff. Mar. 6, 1944 ;-- CL 1948, 712A.19 ;-- Am. 1951, Act 98, Eff. Sept. 28, 1951 ;-- Am. 1966, Act 181, Imd. Eff. July 1, 1966 ;-- Am. 1988, Act 224, Eff. Apr. 1, 1989 ;-- Am. 1994, Act 264, Eff. Jan. 1, 1995 ;-- Am. 1996, Act 16, Eff. June 1, 1996 ;-- Am. 1997, Act 163, Eff. Mar. 31, 1998 ;-- Am. 1998, Act 480, Eff. Mar. 1, 1999 ;-- Am. 1998, Act 530, Eff. July 1, 1999 ;-- Am. 2004, Act 477, Eff. Imd. Eff. Dec. 28, 2004 ;-- Am. 2008, Act 202, Imd. Eff. July 11, 2008 ;-- Am. 2018, Act 58, Eff. June 12, 2018 ;-- Am. 2020, Act 9, Imd. Eff. Jan. 27, 2020

FormerLaw Notes:

    See section 18 of Ch. XII of Act 288 of 1939; and CL 1929, § 12838.

PopularName Notes:

Probate Code

PopularName Notes:

Juvenile Code
Notes of Decisions
Cited in 151 cases (58 in the last 5 years), 1963–2026 · leading case: In Re Mason, 782 N.W.2d 747 (Mich. 2010).
In Re Mason, 782 N.W.2d 747 (Mich. 2010). · cites it 6× “13a(2), review hearings to evaluate the child's and parents' progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
In Re Rood, 763 N.W.2d 587 (Mich. 2009). · cites it 6× “[34] MCL 712A.19(3); MCR 3.966(A)(2); MCR 3.975(C).”
Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). · cites it 8× “MCL 712A.19(3). At each review hearing, the court must evaluate the parent's compliance with the service plan, MCL 712A.”
In re Sanders, 852 N.W.2d 524 (Mich. 2014). · cites it 4× “18f and MCL 712A.19, include “similar requirement[s] during the earlier dispositional hearings.”
In re Blakeman, 926 N.W.2d 326 (Mich. Ct. App. 2018). · cites it 4× “In doing so, the trial court must ensure that it is complying fully with the requirements of MCL 712A.19(6). 7 *339 *341 Vacated and remanded.”
In Re Ap, 770 N.W.2d 403 (Mich. Ct. App. 2009). · cites it 4× “JURISDICTION AND AUTHORITY Petitioner and the child’s attorney mischaracterize the trial court’s decision to award “custody” to Reid as a determination made under MCL 712A.19(1) of the juvenile code and MCR 3.”
In re Gach, 889 N.W.2d 707 (Mich. Ct. App. 2016). · cites it 2× “19(b)(3)(i) does not justify the new termination because it cannot be clearly and convincingly proved that the parent had failed to remedy the earlier abuse or neglect that led to the earlier termination, application of MCL 712A.19(b)(3)(Z) “disdains present realities in…”
People v. Tennyson, 790 N.W.2d 354 (Mich. 2010). · cites it 2× “19b(1); MCL 712A.19(3). As noted above, temporary court custody is distinct from permanent custody, MCL 712A.”
In re Medina, 894 N.W.2d 653 (Mich. Ct. App. 2016). “19b(4)], if a child remains in foster care[ 4 ] in the temporary custody of the *229 court following a review hearing under [MCL 712A.19(3)] or a permanency planning hearing under [MCL 712A.”
In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). · cites it 2× “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”
In re DMK, 796 N.W.2d 129 (Mich. Ct. App. 2010). · cites it 3× “13a(2), review hearings to evaluate the child’s and parents’ progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
In the Matter of LaFlure, 210 N.W.2d 482 (Mich. Ct. App. 1973). · cites it 4× “MCLA 712A.19; MSA 27.3178(598.19). If a neglected child remains in foster care in the temporary custody of the court for two or more years, the court may assume permanent custody of the child if, after a hearing, the child’s parents "fail to establish a reasonable probability”…”
— Mich. Comp. Laws § 712A.19(1) — 6 cases
In Re Ap, 770 N.W.2d 403 (Mich. Ct. App. 2009). “JURISDICTION AND AUTHORITY Petitioner and the child’s attorney mischaracterize the trial court’s decision to award “custody” to Reid as a determination made under MCL 712A.19(1) of the juvenile code and MCR 3.”
In re Dearmon, 303 Mich. App. 684 (Mich. Ct. App. 2014).
In re EP, 234 Mich. App. 582 (Mich. Ct. App. 1999).
In Re Ep, 595 N.W.2d 167 (Mich. Ct. App. 1999).
in Re Benavides Minors (Mich. Ct. App. 2020).
— Mich. Comp. Laws § 712A.19(12) — 1 case
in Re I S Jondall Minor (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 712A.19(2) — 4 cases
In re Detmer/Beaudry, 910 N.W.2d 318 (Mich. Ct. App. 2017).
In Re Jacobs, 444 N.W.2d 789 (Mich. 1989).
in Re detmer/beaudry Minors (Mich. Ct. App. 2017).
in Re detmer/beaudry Minors (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 712A.19(3) — 11 cases
People v. Tennyson, 790 N.W.2d 354 (Mich. 2010). “19b(1); MCL 712A.19(3). As noted above, temporary court custody is distinct from permanent custody, MCL 712A.”
Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). “MCL 712A.19(3). At each review hearing, the court must evaluate the parent's compliance with the service plan, MCL 712A.”
In re Medina, 894 N.W.2d 653 (Mich. Ct. App. 2016). “19b(4)], if a child remains in foster care[ 4 ] in the temporary custody of the *229 court following a review hearing under [MCL 712A.19(3)] or a permanency planning hearing under [MCL 712A.”
In re Sanders, 852 N.W.2d 524 (Mich. 2014). “18f and MCL 712A.19, include “similar requirement[s] during the earlier dispositional hearings.”
In Re Rood, 763 N.W.2d 587 (Mich. 2009). “[34] MCL 712A.19(3); MCR 3.966(A)(2); MCR 3.975(C).”
— Mich. Comp. Laws § 712A.19(3)(G) — 1 case
in Re N I R Elkins Minor (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 712A.19(3)(J) — 1 case
in Re N I R Elkins Minor (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 712A.19(3)(a)(ii) — 1 case
In Re Finnister Minors (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 712A.19(3)(b)(i) — 1 case
In Re E Hitz Minor (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 712A.19(3)(b)(ii) — 2 cases
in Re R R Cameron Minor (Mich. Ct. App. 2016).
In Re N J Moore Minor (Mich. Ct. App. 2026).
— Mich. Comp. Laws § 712A.19(3)(c)(i) — 10 cases
In Re jackisch/stamm-jackisch Minors (Mich. Ct. App. 2022).
In Re Jackisch/Stamm-Jackisch Minors (Mich. Ct. App. 2022).
In Re Jones Minors (Mich. Ct. App. 2022).
In Re gibson/murphy Minors (Mich. Ct. App. 2023).
20231121_C366005_32_366005.Opn.Pdf (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 712A.19(3)(g) — 7 cases
in Re N I R Elkins Minor (Mich. Ct. App. 2016).
in Re J Ferranti Minor (Mich. 2019).
in Re M a McCary-edwards Minor (Mich. Ct. App. 2019).
In Re Thompson Minors (Mich. Ct. App. 2022).
20231121_C366005_32_366005.Opn.Pdf (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 712A.19(3)(j) — 3 cases
in Re N I R Elkins Minor (Mich. Ct. App. 2016).
In Re Jones Minors (Mich. Ct. App. 2022).
In Re tucker/prewitt/gray Minors (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 712A.19(3)(k)(iii) — 1 case
In Re P T Hale Minor (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 712A.19(4) — 2 cases
In re EP, 234 Mich. App. 582 (Mich. Ct. App. 1999).
In Re Ep, 595 N.W.2d 167 (Mich. Ct. App. 1999).
— Mich. Comp. Laws § 712A.19(4)(b) — 1 case
In Re Vasquez, 501 N.W.2d 231 (Mich. Ct. App. 1993).
— Mich. Comp. Laws § 712A.19(4)(d) — 1 case
in Re E Sanchez Minor (Mich. Ct. App. 2019).
— Mich. Comp. Laws § 712A.19(5) — 1 case
In Re Caw, 665 N.W.2d 475 (Mich. 2003).
— Mich. Comp. Laws § 712A.19(5)(c) — 2 cases
Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). “MCL 712A.19(3). At each review hearing, the court must evaluate the parent's compliance with the service plan, MCL 712A.”
In Re Rood, 763 N.W.2d 587 (Mich. 2009). “[34] MCL 712A.19(3); MCR 3.966(A)(2); MCR 3.975(C).”
— Mich. Comp. Laws § 712A.19(6) — 9 cases
In Re Rood, 763 N.W.2d 587 (Mich. 2009). “[34] MCL 712A.19(3); MCR 3.966(A)(2); MCR 3.975(C).”
Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). “MCL 712A.19(3). At each review hearing, the court must evaluate the parent's compliance with the service plan, MCL 712A.”
In re Blakeman, 926 N.W.2d 326 (Mich. Ct. App. 2018). “In doing so, the trial court must ensure that it is complying fully with the requirements of MCL 712A.19(6). 7 *339 *341 Vacated and remanded.”
In re EP, 234 Mich. App. 582 (Mich. Ct. App. 1999).
In Re Ep, 595 N.W.2d 167 (Mich. Ct. App. 1999).
— Mich. Comp. Laws § 712A.19(6)(a) — 7 cases
In Re Mason, 782 N.W.2d 747 (Mich. 2010). “13a(2), review hearings to evaluate the child's and parents' progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
In re Blakeman, 926 N.W.2d 326 (Mich. Ct. App. 2018). “In doing so, the trial court must ensure that it is complying fully with the requirements of MCL 712A.19(6). 7 *339 *341 Vacated and remanded.”
In re DMK, 796 N.W.2d 129 (Mich. Ct. App. 2010). “13a(2), review hearings to evaluate the child’s and parents’ progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
in Re Robinson Minors (Mich. Ct. App. 2016).
in Re Blakeman Minors (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 712A.19(6)(d) — 4 cases
In re Sanders, 852 N.W.2d 524 (Mich. 2014). “18f and MCL 712A.19, include “similar requirement[s] during the earlier dispositional hearings.”
In re Blakeman, 926 N.W.2d 326 (Mich. Ct. App. 2018). “In doing so, the trial court must ensure that it is complying fully with the requirements of MCL 712A.19(6). 7 *339 *341 Vacated and remanded.”
in Re Blakeman Minors (Mich. Ct. App. 2018).
in Re Sanders Minors (Mich. 2014).
— Mich. Comp. Laws § 712A.19(6)(e) — 2 cases
In re Blakeman, 926 N.W.2d 326 (Mich. Ct. App. 2018). “In doing so, the trial court must ensure that it is complying fully with the requirements of MCL 712A.19(6). 7 *339 *341 Vacated and remanded.”
in Re Blakeman Minors (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 712A.19(7) — 3 cases
In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”
in Re burkhart/odil Minors (Mich. Ct. App. 2019).
in Re olive/metts Minors (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 712A.19(7)(a) — 5 cases
In Re Mason, 782 N.W.2d 747 (Mich. 2010). “13a(2), review hearings to evaluate the child's and parents' progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
In Re Rood, 763 N.W.2d 587 (Mich. 2009). “[34] MCL 712A.19(3); MCR 3.966(A)(2); MCR 3.975(C).”
Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). “MCL 712A.19(3). At each review hearing, the court must evaluate the parent's compliance with the service plan, MCL 712A.”
In re DMK, 796 N.W.2d 129 (Mich. Ct. App. 2010). “13a(2), review hearings to evaluate the child’s and parents’ progress, MCL 712A.19, permanency planning hearings, MCL 712A.”
in Re J J Hendrickson Minor (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 712A.19(8) — 4 cases
In re Sanders, 852 N.W.2d 524 (Mich. 2014). “18f and MCL 712A.19, include “similar requirement[s] during the earlier dispositional hearings.”
in Re a M Daniels Minor (Mich. Ct. App. 2016).
In Re a R Deaibes Minor (Mich. Ct. App. 2025).
in Re Sanders Minors (Mich. 2014).
— Mich. Comp. Laws § 712A.19(8)(b) — 2 cases
In Re Jacobs, 444 N.W.2d 789 (Mich. 1989).
Dep't of Soc. Servs. v. Smith, 433 Mich. 24 (Mich. 1989).
— Mich. Comp. Laws § 712A.19(B)(3)(c)(i) — 1 case
In Re S Jones Minor (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 712A.19(B)(3)(c)(ii) — 1 case
In Re S Jones Minor (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 712A.19(b) — 2 cases
Rebecca Jasinski v. Sheri Tyler, 729 F.3d 531 (6th Cir. 2013).
In Re B Bennett Minor (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 712A.19(b)(1) — 1 case
In Re B Bennett Minor (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 712A.19(b)(3) — 8 cases
in Re N B Ginns Minor (Mich. Ct. App. 2017).
in Re N B Ginns Minor (Mich. Ct. App. 2017).
in Re Sirbaugh Minors (Mich. Ct. App. 2018).
In Re J D Robinson Minor (Mich. Ct. App. 2021).
20231214_C366310_49_366310.Opn.Pdf (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 712A.19(b)(3)(Z) — 1 case
In re Gach, 889 N.W.2d 707 (Mich. Ct. App. 2016). “19(b)(3)(i) does not justify the new termination because it cannot be clearly and convincingly proved that the parent had failed to remedy the earlier abuse or neglect that led to the earlier termination, application of MCL 712A.19(b)(3)(Z) “disdains present realities in…”
— Mich. Comp. Laws § 712A.19(b)(3)(a) — 2 cases
in Re L D Rippy Minor (Mich. Ct. App. 2019).
Placeholder name (Mich. Ct. App. 2026).
— Mich. Comp. Laws § 712A.19(b)(3)(a)(i) — 2 cases
In Re O O Claudio-Perez Minor (Mich. Ct. App. 2022).
In Re D L N Murphy Minor (Mich. Ct. App. 2026).
— Mich. Comp. Laws § 712A.19(b)(3)(a)(ii) — 4 cases
In Re coleman/hayes/barfield Minors (Mich. Ct. App. 2023).
In Re S M Barfield Minor (Mich. Ct. App. 2023).
In Re a R Downey Minor (Mich. Ct. App. 2023).
In Re K a P Harris-Buchanan Minor (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 712A.19(b)(3)(b)(i) — 2 cases
In Re shepherd/wakefield Minors (Mich. Ct. App. 2023).
In Re K a P Harris-Buchanan Minor (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 712A.19(b)(3)(b)(ii) — 2 cases
in Re yurkus/jones Minors (Mich. Ct. App. 2018).
in Re yurkus/jones Minors (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 712A.19(b)(3)(c)(i) — 13 cases
in Re M J Dawkins Minor (Mich. Ct. App. 2019).
in Re Herber Minors (Mich. Ct. App. 2018).
in Re Herber Minors (Mich. Ct. App. 2018).
in Re a a Ehrlich Minor (Mich. Ct. App. 2018).
in Re Neahusan Minors (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 712A.19(b)(3)(c)(ii) — 3 cases
in Re M J Dawkins Minor (Mich. Ct. App. 2019).
In Re vary/wilson Minors (Mich. Ct. App. 2022).
In Re vary/wilson Minors (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 712A.19(b)(3)(d) — 1 case
In Re I B Gillmore Minor (Mich. Ct. App. 2026).
— Mich. Comp. Laws § 712A.19(b)(3)(g) — 13 cases
in Re M J Dawkins Minor (Mich. Ct. App. 2019).
in Re P E K Shannon Minor (Mich. Ct. App. 2017).
in Re P E K Shannon Minor (Mich. Ct. App. 2017).
in Re a M L Butler Minor (Mich. Ct. App. 2017).
in Re a M L Butler Minor (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 712A.19(b)(3)(h) — 1 case
in Re B M Baham Minor (Mich. Ct. App. 2020).
— Mich. Comp. Laws § 712A.19(b)(3)(i) — 4 cases
In re Gach, 889 N.W.2d 707 (Mich. Ct. App. 2016). “19(b)(3)(i) does not justify the new termination because it cannot be clearly and convincingly proved that the parent had failed to remedy the earlier abuse or neglect that led to the earlier termination, application of MCL 712A.19(b)(3)(Z) “disdains present realities in…”
in Re Nl Benson Minor (Mich. Ct. App. 2017).
in Re Nl Benson Minor (Mich. Ct. App. 2017).
In Re Charles Minors (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 712A.19(b)(3)(j) — 2 cases
In Re D D Cooper Minor (Mich. Ct. App. 2024).
In Re K Hemmeke Minor (Mich. Ct. App. 2026).
— Mich. Comp. Laws § 712A.19(b)(3)(l) — 3 cases
in Re Nl Benson Minor (Mich. Ct. App. 2017).
in Re Nl Benson Minor (Mich. Ct. App. 2017).
D in Re Bates Minors (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 712A.19(b)(5) — 2 cases
In Re M J Lyda Minor (Mich. Ct. App. 2022).
In Re Riley Minors (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 712A.19(b)(c)(3)(g) — 1 case
In Re Fox Minors (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 712A.19(b)(c)(i) — 3 cases
20231214_C366310_49_366310.Opn.Pdf (Mich. Ct. App. 2023).
20221215_C361231_39_361231.Opn.Pdf (Mich. Ct. App. 2022).
In Re D a Thurston Minor (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 712A.19(b)(c)(ii) — 1 case
in Re Westen Minors (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 712A.19(b)(ii) — 3 cases
in Re Wood Minors (Mich. Ct. App. 2017).
in Re Wood Minors (Mich. Ct. App. 2017).
in Re glass/hendrix Minors (Mich. Ct. App. 2018).
— Mich. Comp. Laws § 712A.19(c)(i) — 1 case
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