The Michigan Court of Appeals has vacated a trial court’s order terminating the parental rights of an incarcerated father, finding that the Michigan Department of Health and Human Services made no reasonable efforts toward reunification.

The trial court properly held that it was in the minor-child’s best interests to terminate the respondent-father’s parental rights, even though it “clearly erred” in finding that the child had a “lack of extended family support,” the Michigan Court of Appeals has ruled.