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

Holding that termination was in the children’s best interests, the court affirmed termination of respondent-father’s parental rights. It rejected his argument that termination was not in the children’s best interests. First, he contended “the trial court simply indicated that the children’s best interests supported termination without properly considering the best-interest factors. This contention is not supported by the record.” Second, he asserted that “the best-interest factors favored him because he had a strong bond with his children; he had parenting ability because he parented the children since birth; and he had income, so he could provide permanency and stability.” He also argued that “the home of a stranger had a serious disadvantage over his home because a father’s love would be absent in a foster home.” And he contended that he “substantially complied with the parent-agency treatment plan.” Again, the record did not support these arguments. It appeared he “erroneously evaluated this factor from his perspective, not the children’s.” Further, the children “had no or little bond with respondent but had strong bonds with their foster parents.” Third, the record did “not support the assertion that respondent had parenting ability simply because he raised them. Throughout this case, respondent showed that he did not develop appropriate parenting skills and could not meet his children’s basic needs. Respondent participated in some services, but he failed to attend others, and did not learn from the services that he attended.” His failure to “complete or comply with his parent-agency plan, including addressing his domestic violence history, negatively impacted his parenting skills.” Fourth, he failed to “explain how his source of income (approximately $800 per month) can provide permanency and stability for his children.” Fifth, he argued that “the foster parents could not provide a father’s love because they were not biological parents.” But he provided “no citation for the argument that a foster parent is innately unable to provide a father’s love to children.” The court was not convinced the trial court made a mistake in its review of the best interest factors and its conclusion that a preponderance of the evidence showed “termination was in the children’s best interests.”