e-Journal Summary

e-Journal Number : 73855
Opinion Date : 09/10/2020
e-Journal Date : 09/21/2020
Court : Michigan Court of Appeals
Case Name : In re Ryans
Practice Area(s) : Termination of Parental Rights
Judge(s) : Per Curiam - Redford, Beckering, and M.J. Kelly
Full PDF Opinion
Issues:

Termination under § 19b(3)(c)(i); Principle that only one statutory ground is needed; In re HRC; Child’s best interests; In re Olive/Metts Minors; In re Moss Minor; In re Frey

Summary

Holding that § (c)(i) was established and that termination of respondent-father’s parental rights was in the child’s best interests, the court affirmed. It held that in “addition to not rectifying his inability to regulate his emotions, respondent did not show that he rectified the problems with his parenting skills. Instead, respondent insists that he was a good parent and that the testimony showing that he physically abused his child was made up by people—such as the child’s mother—who had reason to lie.” In doing so, he did “not acknowledge that the child psychological evaluation included the child’s disclosure that respondent had hit him and that the child was fearful of respondent. Moreover, the fact that witnesses to the abuse had reason to be biased against respondent does not strip their testimony of all credibility and make it impossible for the court to credit their testimony.” In addition to denying responsibility for the child coming into care, he “was only partially compliant with the recommended parenting classes.” While he was hostile to the parenting-class provider, he “partially complied with the supervision component of the parenting class. Respondent did not participate in the education component of” the class. Overall, testimony that he “had previously physically abused the child and was now refusing to participate fully in parenting classes to improve his parenting skills supports the trial court’s finding that the conditions leading to adjudication continued to exist and would not be rectified in a reasonable time considering the child’s age.”

Full PDF Opinion