The Court of Appeals reversed the trial court order terminating parental rights that was based primarily on the doctrine of anticipatory neglect because the evidence did not demonstrate that the child at issue was subject to the same risk of harm as the other child who had been abused by the parent 8 years prior and under very different circumstances.

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.