Best interests of the child; MCL 712A.19b(5); In re Olive/Metts Minors

Holding that termination was in the child’s best interests, the court affirmed termination of respondent-father’s parental rights. He did not argue on appeal that the trial court erred in finding statutory grounds for termination existed. The trial court found that despite respondent being offered “very extensive services,” he failed to complete or benefit from them enough to have the child placed with him, or to cooperate or communicate with the DHHS during the case, and remained “no closer to reunifying with his child than at the start of the case.” In addition, it found he was “incapable of providing this child with a caring, stable environment.” On appeal, respondent claimed termination did not serve the child’s best interests because he had sufficient parenting ability, his rights to the child’s siblings were not terminated, the child would not be easily adopted, and the parent-child bond declined only because of the suspension of his parenting time. The court disagreed. First, the trial court appropriately found that the child “would require consistent, stable care in a calm environment,” and her “emotional stability would be greatly disturbed with the ‘drama, instability, insecurity that [respondent] could create if he still retained his parental rights.’” Further, while the trial court “originally suspended parenting time, respondent’s own actions and inactions prevented parenting time from being reinstated. The trial court cannot be blamed for the diminishment of his bond with” the child. Finally, despite his “demonstrated ability to care for his older, average-needs children, he continued to lack the skills to parent” the child and provide for her special needs. The trial court “considered and weighed the applicable best-interest factors and none of these factors tended to favor respondent.”