Termination under § 19b(3)(c)(i); Failure to make meaningful change; In re Williams; Failure to participate in & benefit from the services offered; In re Atchley; Best interests of the child; In re White; Relative placement; MCL 712A.19a(8)(a)

Holding that § (c)(i) was met and that termination was in the child’s best interests, the court affirmed termination of respondent-mother’s parental rights. Her rights were terminated on the basis of untreated mental health issues, substance abuse issues, and abandonment. On appeal, the court rejected her argument that the DHHS failed to prove a statutory ground for termination. “The record establishes respondent had not accomplished any meaningful change in the conditions that led to adjudication . . . .” For the majority of this case, she “refused to make efforts to address her substance abuse and mental health issues; she only began participating in services after the supplemental petition was filed.” In addition, she “failed to take even one of the 27 scheduled drug screens prior to the termination hearing.” And even if she “completed a drug screen on the day of the termination hearing, that was insufficient to show she was addressing her substance abuse issue.” The court also rejected her claim that termination was not in the child’s best interests. The trial court acknowledged the child’s “placement with her grandparents, but found the need to provide her with stability and permanency outweighed the fact that she was placed with relatives.” Respondent demonstrated she was not committed to reunifying with the child “through her lack of compliance with her case service plan until after the supplemental petition was filed.” She also showed her disinterest in reunifying with the child by only visiting her 9 of the 47 times she could have. In addition, the child “was bonded with her grandparents and never spoke of respondent. There was no evidence presented that respondent had a bond with [the child], apart from respondent’s own testimony. The caseworker opined that terminating respondent’s parental rights would provide [the child] with permanence, stability, finality, and safety.”