Termination under §§ 19b(3)(b)(i), (b)(ii), & (j); In re VanDalen; In re BZ; In re HRC; Claim that the trial court did not comply with MCR 3.971(B); In re Ferranti; MCR 3.971(B)(1), (3), & (4); Due process; In re Pederson; MCR 3.920(G); MCR 3.920(B)(3)(d)

Holding that §§ (b)(i), (b)(ii), and (j) existed, and rejecting respondent-mother’s due process claim, the court affirmed termination of both respondents-parents’ parental rights to their child, M. Respondent-father argued that the trial court erred by terminating his parental rights pursuant to § (j) because there was no indication that his past crimes or alcohol use would likely cause harm to M. “Given his history of physically harming children in his care and custody and the likelihood that [he] would face environmental stressors upon his release,” the court could not conclude that the trial court committed reversible error in determining that § (j) supported termination. Also, the trial court did not err by terminating the mother’s parental rights pursuant to §§ (b)(i), (b)(ii), and (j). She did not contest that she broke M’s arm, causing him physical injury, but argued that the trial court erred by holding “that there was a reasonable likelihood that he would suffer further harm in her care.” However, the mother was drinking when the injury occurred. Her neighbor testified that the mother “drank daily and that it seemed to interfere with her ability to parent. Four out of nine parenting time visits were cancelled because” the mother was intoxicated. Her intoxication resulted in the removal of M’s sibling, and the mother “had to restart her substance abuse classes because of her failure to appear at them.” Under the circumstances, the trial court did not err by concluding that M “likely would be injured again if returned to his mother while her substance abuse problem continued to be out of control and that termination of” the mother’s parental rights were in M’s best interests. As to her claim regarding MCR 3.971(B), the court could not conclude that her plea to jurisdiction “was unknowing or involuntary.”