In Re Brooks Minors

Michigan Court of Appeals·Decided July 17, 2026·No. 379585·Unpublished

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

UNPUBLISHED July 17, 2026 9:47 AM

In re BROOKS, Minors.

No. 379585 Newaygo Circuit Court Family Division LC No. 25-010106-NA

Before: ACKERMAN, P.J., and REDFORD and FEENEY, JJ.

PER CURIAM.

Respondent appeals as of right the trial court’s order terminating his parental rights to his two minor children RB and BB under MCL 712A.19b(3)(b)(i) (parents act caused injury or sexual abuse to child or child’s sibling), (j) (reasonable likelihood of harm if returned to parent), and (k)(ii) (criminal sexual conduct involving the child’s sibling). We affirm.

I. FACTUAL BACKGROUND

Respondent is BB’s and RB’s biological father. The children’s mother was a respondent;

however, she retained her parental rights to both children. Respondent is also the biological father of SB and the stepfather of EE.1 SB and EE are both over the age of 18 years and are not the children at issue in this proceeding. BB and RB are in their paternal grandmother’s care and custody.

In February 2025, SB contacted Children’s Protective Services (CPS) and told them that respondent had sexually abused and raped her when she was in seventh grade. SB also told CPS that respondent had sexually abused her half sister EE. SB was then interviewed twice, and she stated that respondent would touch her breasts and “down there,” referring to her vagina. SB also

1 EE shares the same mother as SB, BB, and RB.

stated that respondent would rape her at night and tell her that she was the only one he wanted. SB also explained that she did not tell anyone because respondent threatened to kill her dog.

The state police also interviewed EE, and she confirmed that respondent would touch her breasts and buttocks and make inappropriate and “awkward” comments like “you really filled out” and “you’re all grown up now.” Both SB and EE also reported extensive physical abuse that occurred in the home. There was also a detailed history of substantiated CPS cases involving physical abuse by respondent of EE, GB2, and SB, as well as domestic violence against the children’s mother, his spouse. The Department of Health & Human Services petitioned to terminate respondent’s parental rights regarding BB and RB because of the sexual abuse alleged by SB and EE.

In August 2025, the preliminary hearing for the petition was held. SB and EE both testified about the sexual abuse and physical abuse that they endured from respondent. The trial court then authorized the petition determining that a preponderance of evidence supported a finding that there was probable cause to believe that the facts alleged in the petition were true. The trial court specifically relied on SB’s and EE’s testimony.

Respondent requested an adjudication bench trial. Petitioner requested that the transcript from the preliminary hearing be entered into evidence. The trial court allowed the admission of the transcript as evidence, and petitioner rested its case. Respondent then testified, during which he generally denied the allegations in the petition and stated that, during the time when SB alleged that the abuse occurred, he was not home alone with her because he was at his mother’s house or working. Respondent also testified that both SB and EE had “very low” cognitive function. The paternal grandmother also testified, and she explained that she received guardianship of SB because SB needed a guardian in light of her developmental disability. SB also testified again, during which she again detailed the sexual abuse by respondent.

The trial court issued a written opinion determining, in relevant part, that a preponderance of evidence supported the finding that BB and RB needed protection; that respondent failed to provide a safe and suitable home environment; and that the children were at a substantial risk of harm because of respondent’s “neglect, physical abuse, and failure to maintain a safe and clean home environment.” The trial court also specifically found that “the testimony and evidence presented establish a pattern of neglect, physical abuse, and an unfit home environment, creating a substantial risk of harm to the minors’ physical and mental well-being.”

In January 2026, the termination and disposition hearing was held. Petitioner again reminded the trial court that child-protective proceedings are considered one continuous proceeding and further reminded the trial court of the testimony presented at the preliminary hearing and adjudication trial, and that the preliminary hearing transcript had been admitted into evidence. Petitioner then presented the testimony from BB’s and RB’s therapist and the CPS worker assigned to the matter. Respondent then testified again and presented the testimony of the children’s mother and two friends.

2 GB was one of respondent’s children. She is now deceased.

In a written opinion, the trial court terminated respondent’s parental rights regarding BB and RB pursuant to MCL 712A.19b(3)(b)(i), (j), and (k)(ii). The trial court specifically found that the pattern of physical abuse as described by SB and EE established neglect, and that the testimony of EE and SB about respondent’s sexual abuse were “credible and corroborated.” Further, the trial court found that SB’s consistent testimony of respondent’s sexual abuse met the clear and convincing evidence standard required for termination. The trial court also determined that termination was in BB’s and RB’s best interests considering the pattern of physical and sexual abuse and BB’s express desire not to return to respondent’s care.

This appeal follows.

II. LEGAL ANALYSIS

A. DUE PROCESS

Respondent first argues, for various reasons,3 that his due-process rights were violated when the trial court terminated his parental rights. We disagree.

Generally, we review de novo whether a child-protective proceeding complied with a parent’s right to due process. In re Sanders, 495 Mich 394, 403-404; 852 NW2d 524 (2014). However, respondent did not preserve this issue for appeal; therefore, we review unpreserved claims of constitutional errors and adjudication errors that are raised after the trial court has terminated parental rights for plain error. In re Ferranti, 504 Mich 1, 29; 934 NW2d 610 (2019); In re VanDalen, 293 Mich App 120, 135; 809 NW2d 412 (2011).

“To avoid forfeiture under the plain error rule, three requirements must be met: 1) the error must have occurred, 2) the error was plain, i.e., clear or obvious, 3) and the plain error affected substantial rights.” VanDalen, 293 Mich App at 135 (quotation marks and citations omitted). “An error has affected a party’s substantial rights when there is a showing of prejudice, i.e., that the error affected the outcome of the lower court proceedings.” In re Pederson, 331 Mich App 445, 463; 951 NW2d 704 (2020) (quotation marks and citation omitted). Further, a clear or obvious error “is one that is not subject to reasonable dispute.” Id. (quotation marks and citation omitted). The outcome of the proceeding will not be reversed unless the plain error “seriously affect[ed] the integrity, fairness, or public reputation of the judicial proceedings.” In re MOTA, 334 Mich App 300, 311; 964 NW2d 881 (2020).

“Parents have a significant interest in the companionship, care, custody, and management of their children, and the interest is an element of liberty protected by due process.” Sanders, 495 Mich at 409 (quotation marks and citation omitted). Respondent is not advancing a procedural due-process claim, i.e., notice and opportunity to be heard; instead, his pleadings suggest he is advancing a substantive due-process claim. “The essence of a substantive due process claim is the arbitrary deprivation of liberty or property interests.” In re TK, 306 Mich App 698, 706; 859

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