e-Journal Summary

e-Journal Number : 72920
Opinion Date : 04/23/2020
e-Journal Date : 05/05/2020
Court : Michigan Court of Appeals
Case Name : In re Start/Snell
Practice Area(s) : Termination of Parental Rights
Judge(s) : Per Curiam - Gadola, Stephens, and Shapiro
Full PDF Opinion
Issues:

Termination under §§ 19b(3)(c)(i), (g), & (i); In re Keillor; In re Ellis; In re Williams; In re Foster; Children’s best interests; In re Gonzales/Martinez; In re Medina; In re White; In re Mason; In re Moss Minors; In re Trejo Minors

Summary

Holding that § (c)(i) exited and termination of respondent-mother’s parental rights was in the children’s best interests, the court affirmed. The case arose when the youngest child, A, tested positive at birth for hydrocodone in late 2017. Respondent contended “that she demonstrated that she was making progress rectifying the conditions that were barriers to reunification. In the more than 14 months after the children’s removal, respondent failed to accomplish any meaningful change in the conditions that led to the trial court assuming jurisdiction of the minor children.” The conditions that led to the adjudication were her “substance abuse, lack of housing, lack of stable income, lack of parenting skills, mental health instability, and domestic violence with the children’s father.” The trial court found that she continued to communicate with the “father and lied to the foster care worker about those communications, suggesting that she had not benefitted from domestic violence counseling. Respondent continued to exhibit poor parenting skills, missing the children’s medical visits and making excuses such as needing to walk her dog or pay her bills. Respondent also was not receptive to the children’s trauma, blaming it on the DHHS.” The trial court observed that she “had not met with her housing program caseworker and was at risk of losing her housing, and had not obtained employment.” In sum, over "182 days had elapsed since the issuance of the initial disposition order and the conditions that led to the trial court assuming jurisdiction of the children persisted.”

Full PDF Opinion