Termination under § 19b(3)(c)(i); Child’s best interests; MCL 712A.19b(5); In re Olive/Metts Minors; Relative placement; In re Schadler; Parent-child bond

Holding that § (c)(i) was met, and that termination was in the child’s (DLT) best interests, the court affirmed termination of respondent-mother’s parental rights. Her rights were terminated on the basis of the child’s testing positive for drugs upon birth, as well as the mother’s challenges with substance abuse and mental health, lack of desire to parent, and unstable housing. On appeal, the court rejected her argument that a statutory ground for termination was not met, finding § (c)(i) was met. “[D]espite receiving a considerable number of services aimed at addressing her substance abuse and mental health issues, mother relapsed about a year after the initial disposition, and failed to demonstrate that she benefited from the services in which she participated.” The foster-care worker testified that she “likewise failed to progress beyond one hour of supervised visitation per week in the time that elapsed since DHHS filed the initial petition. The foster-care worker believed it would take a significant amount of time for mother to demonstrate her ability to remain substance-free, obtain independent housing, and provide permanency for DLT.” As such, the testimony “indicated there was no reasonable likelihood that mother would be able to rectify the conditions that brought DLT into care within a reasonable time considering DLT’s age.” The court also rejected her claim that termination was not in the child’s best interests. “DHHS presented evidence that mother’s parenting ability was poor when living outside of a structured environment. [Her] interactions with DLT were positive during their supervised visitation before mother relapsed, but mother stopped participating in visitation” for several months as a result of her relapse. There was some evidence of a bond, but the record showed “mother was only able to appropriately parent DLT in a time-limited, supervised setting.” Her involvement in the child’s “life became nonexistent during periods of relapse, suggesting that she would not be able to provide stability for DLT in the long term.” In contrast, “DLT had a stable and healthy home environment with her legal father, who was capable of meeting her needs.” In addition, the “foster-care worker testified that DLT’s health issues had improved while in her legal father’s care.” The trial court “considered DLT’s placement with her legal father and ultimately determined that DLT’s placement with a relative did not outweigh the ‘significant issues’ mother had to overcome ‘in order to be a safe and stable parent for [DLT].’”