Termination under §§ 19b(3)(c)(i) & (g); Harmless error; Whether the trial court improperly focused on respondent’s marijuana use; Distinguishing In re Richardson; Credibility assessments; Child’s best interests; MCL 712A.19b(5); In re White; Effect of relative placement; MCL 712A.19a(6)(a); Family Engagement Therapy (FET)

While the court found that the trial court erred in determining § (g) was established, it held that this error was harmless because § (c)(i) supported termination of respondent-mother’s parental rights to the child (W). It also concluded that terminating her parental rights was in W’s best interests. Thus, the court affirmed the termination order. Over 182 elapsed between the initial depositional order and the termination decision. “Respondent’s barriers at adjudication were identified as (1) substance abuse, (2) mental health, (3) parenting skills, (4) housing, and (5) employment. As of the termination hearing, while respondent’s substance-abuse barrier had been somewhat addressed, none of the other barriers had been resolved. Respondent continued to display emotional dysregulation through her interactions with her caseworkers and the trial court.” The court noted that her parenting time was twice suspended during the case due to “her failure to properly engage with children, and she regularly changed both jobs and housing throughout the” case. She also did not rectify the conditions that brought W “into care despite being given more than three years to do so and countless opportunities to participate in services. Respondent failed to meaningfully engage in services until late in the case, and, even at that point, did not show any initiative to seek help outside FET.” As a result, the court held that sufficient evidence was “presented that the conditions that led to adjudication would not be rectified in a reasonable amount of time given” W’s age. As to W’s “best interests, the trial court considered respondent’s poor bond with” him and her inability to understand his special needs. In addition, it considered her “failure to improve her parenting skills and [W’s] bond with his current placement providers, who were willing and able to adopt and care for him properly.” Although his caregivers were relatives, “this singular factor weighing against termination does not countermand the numerous factors weighing in favor of” it. The court noted “respondent’s longstanding history of not engaging in services during the case, along with the incredibly long period [W] was in care, which constituted the majority of his life, and the large number of moves between caregivers during that time.”