The Court of Appeals affirmed the termination of a mother's parental rights because she was the victim of domestic violence in In re Hopkins-Webster (unpublished August 13, 2013, Docket 315194). The opinion is troubling. It does not appear that the child was a victim of domestic violence or that mother failed to protect the child. For certain, she was somewhat in denial about her status as a domestic violence victim and continued to live with the abuser. When she complained on appeal that the DHS did not offer enough reunification services, the Court of Appeals responded that DHS does not have to provide services when "termination is the goal."

Once again, the COA cited In re HRC for this proposition, but HRC was a very different case - in In re HRC there were aggravated circumstances which by statute allows a trial court to terminate parental rights at the initial dispositional hearing and without any reunification services. The Court of Appeals should not rely on HRC to deny services in a non-aggravated circumstances case. This issue is being challenged in the Michigan Supreme Court in In re Moss (Supreme Court Docket 147519).