Termination under §§ 19b(3)(a)(ii) & (g); In re VanDalen; In re HRC; Reunification; In re B & J; Abandoned issue; Marx v. Department of Commerce; Child’s best interests; In re Moss Minors; In re Olive/Metts Minors; In re Frey; Temporary placement; Whether the trial court complied with MCR 3.977(H)(1) & (I)(3); In re Utrera; Whether the trial court stated the child’s best interests in making its findings

The trial court properly terminated the respondent-mother’s parental rights to the child where the statutory grounds for termination were established by clear and convincing evidence and it was in the child’s best interests. Presuming, without deciding, that she did not desert the child pursuant to § (a)(ii), the court held that the trial court did not clearly err in finding clear and convincing evidence to terminate her parental rights under § (g). Under § (g), a trial court may terminate parental rights when it is proven by clear and convincing evidence that “[t]he parent, without regard to intent, fail[ed] to provide proper care or custody for the child and there is no reasonable expectation that the parent will be able to provide proper care and custody within a reasonable time considering the child’s age.” She admitted to having a substance abuse problem and took no meaningful steps to rectify it. She also failed to have stable housing or gainful employment at any point during the proceeding. Respondent exhibited no means of being able to provide for the child at the time of termination or within a reasonable time considering the child’s age. Thus, the trial court did not clearly err by terminating her parental rights under § (g). Affirmed.