Termination under §§ 19b(3)(c)(i), (g), & (j); A parent’s failure to comply with the parent-agency agreement as evidence of failure to provide proper care & custody for the child; In re JK; Best interests of the children; MCL 712A.19b(5); In re Olive/Metts Minors

Holding that multiple statutory grounds were met, and that termination was in the children’s best interests, the court affirmed termination of respondent-mother’s parental rights. Her rights were terminated “based on her continued substance abuse and lack of sufficient progress in various services to address other areas of concern.” On appeal, the court rejected her argument that the DHHS failed to prove a statutory ground for termination. As to § (c)(i), “[g]iven the slow progress respondent made through services, it was unlikely that” she could rectify the conditions leading to adjudication within a reasonable time. In addition, as to § (g), “[g]iven respondent’s continuing struggle with substance abuse, fluctuating emotional stability, and inability to understand the children’s needs, there is no likelihood that respondent would be able to provide proper care and custody within a reasonable time.” Further, as to § (j), there was a high probability that the children “would again be placed in danger of physical and emotional harm if returned to respondent’s care.” The court also rejected her claim that termination was not in the children’s best interests. They “grew up in a home full of domestic violence and drug use. This left them emotionally scarred and traumatized.” Upon their removal, they “exhibited concerning behaviors and indications of trauma.” However, respondent “never truly acknowledged her role in harming her children and never gained a full understanding of their needs. She continued to feed into their fears of their father and caused them anxiety.” Moreover, she “remained unable to provide permanence for her children in a safe and stable household. [She] herself remained emotionally unstable after 17 months of treatment and had yet to achieve sobriety. She had difficulty maintaining employment and had not secured housing.”