MSC: DHS Reunification Plans unreasonable if not tailored to Respondent's needs

Writing in this week in In Re Hicks/Brown, the Michigan Supreme Court recently held that the Michigan Department of Health and Human Services (DHS) reunification plans must take into consideration the disabilities of the parents in order to be considered 'reasonable.'

In Hicks, a parent with an intellectual disability was successful in reversing the termination of her parental rights. The reversal was granted on the basis that her disability was not accommodated within her DHS reunification plan.

The Michigan Probate Code requires DHS to make reasonable efforts to reunify a family before seeking the termination of parental rights from a parent. The Court found that the 'reasonableness' includes compliance with provisions within the American Disabilities Act.

In Re Hicks/Brown is relevant to families currently navigating the juvenile court system. If you have questions, or would otherwise like to know more about navigating the juvenile court system, please contact my firm by clicking here.

Full Text of In Re Hicks/Brown found here, courtesy of

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