Child’s best interests; Placement with relatives
Holding that the trial court’s finding that the termination of respondent-father’s parental rights was in the child’s best interests was not clearly erroneous, the court affirmed the trial court order terminating his parental rights to the child under MCL 712A.19b(f). The child “was only a few months old when she started living with the guardians. At the time of termination, the child had been in the care of the guardians for 75% of her life.” During that time, respondent “saw the child only a handful of times, and he admitted that the child would not recognize him because the child had not seen him since she was one year old. Accordingly, there is no indication in the record that [respondent] shared an appropriate parent-child bond with the child at the time of termination.” Further, the record supported the trial court’s finding that he “could not provide stability and permanency for the child in the future, because he had failed to do so during the proceedings.” The evidence showed that respondent “has been in and out of incarceration for most of his adult life.” Additionally, respondent “was homeless and agreed that the child should remain in the care of the child’s guardians because of his unstable living situation. [Respondent] adamantly acknowledged that the child was well taken care of and that the guardians were the perfect candidates to raise the child.” This evidence supported “the conclusion that the guardians have, and will continue to, provide stability and permanency for the child. As the trial court correctly pointed out, [respondent] had many opportunities to establish some sort of relationship with the child and had failed to do so; therefore, the evidence provided a strong inference that he would not now suddenly change his living situation that had been the same his entire adult life.” The court noted that at “the termination hearing, the trial court specifically addressed the lack of bond between the child and” respondent. In doing so, it reviewed his “incarceration history and domestic violence history, as well as his previous inability to care for the child. The court specifically recognized [her] excellent relationship with her guardians and that the child already had permanency and stability. In making this determination, the court appropriately reviewed the various considerations, including the child’s bond with [respondent], any domestic violence history, residential permanency, stability, and the advantages and opportunities for the child to thrive in the guardians’ home. The court’s findings were not clearly erroneous.”
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