Termination under the Adoption Code; MCL 710.51(6); In re Hill; In re ALZ; In re Talh; Principle that an incarcerated parent may still retain the ability to comply with the support requirements of MCL 710.51(6); In re Caldwell; Principle that attempts to communicate by letters & phone calls are not regular or substantial contacts within the meaning of MCL 710.51(6)(b); In re Kaiser; Waiver; In re Ferranti; Elahham v. Al-Jabban; Varran v. Granneman; Requirement that the trial court consider the children’s best interests before approving their adoption; MCL 710.22(g); MCL 710.51(1)(b); In re Newton; Best interests of the children; MCL 712A.19b(5); In re Olive/Metts Minors; Correction of clerical errors; MCR 6.435(A); MCR 7.216(A)(4)

Holding that there were grounds for termination of respondent-mother’s parental rights to the children under the Adoption Code, and that termination was in the children’s best interests, the court affirmed termination of her parental rights, but remanded for the ministerial task of correcting clerical errors in the termination orders. Petitioner-father sought termination of respondent’s parental rights to their children for purposes of stepparent adoption. The trial court found that clear and convincing evidence established grounds for termination under MCL 710.51(6), and that termination was in the children’s best interests. On appeal, the court rejected her argument that the trial court erred by finding that the evidence supported termination under the Adoption Code. It noted the record supported that “during the requisite two-year review period, [she] had the ability to support or assist in supporting the children, but she failed or neglected to provide regular and substantial support” and that she “failed to make the children a priority in her life and neglected to visit them.” Further, she “expressly waived any objection to the admission of” alleged hearsay and “abandoned her claim of error regarding the admissibility of” petitioner’s testimony. Meanwhile, it noted that, “[i]n filling out the form order, the trial court checked the wrong box on each of the orders it entered. Because [its] ruling from the bench does not indicate a substantive error but only a clerical error, the clerical errors require correction.” Finally, it rejected her contention that termination was not in the children’s best interests, finding she “lacked the ability to provide the children stability and permanence of the type that would foster” their development, “lacked the ability to provide meaningful parental guidance,” had a “history of committing domestic violence” against family members, and “had a substance abuse problem that interfered with her ability to parent and be present for the children.”