Termination under §§ 19b(3)(a), (g), (j), & (k); The trial court’s findings of fact & conclusions of law; MCR 3.977(I)(1); In re Pawloski; Effect of exposing the children to harm; In re Plump; Children’s best interests

Holding that the trial court failed to make findings of fact supporting a statutory ground to terminate respondent-father’s parental rights, the court vacated in part as to him, and remanded. In addition, holding that § (j) was met as to respondent-mother, and that termination of her parental rights was in the children’s best interests, the court affirmed termination of her parental rights. Respondents’ parental rights were terminated on the basis of the “mother’s continued relationship with an abusive partner despite multiple incidents involving domestic violence resulted in her oldest child sustaining life-threatening injuries.” On appeal, the court first addressed the termination of the father’s parental rights. “Because the trial court failed to make any findings of fact supporting its determination that the evidence satisfied a statutory basis for termination, we vacate in part the trial court’s . . . order following the adjudication and statutory-grounds hearing with respect to [him] only and remand for the trial court to make findings of fact in support of at least one statutory basis for terminating” his parental rights. “Having vacated its statutory-grounds determination with respect to the father, we likewise vacate in part the” order terminating his parental rights only. As to the mother, it found that while the record did not support termination of her parental rights under §§ (a), (g), and (k), it did support termination under § (j). The court noted that her tolerance of abuse by one of the children’s father’s “over a period of years exposed her children to harm, which ultimately nearly killed her oldest child.” And the record supported the trial court’s determination that she “failed to demonstrate that she recognizes the danger to which she subjected her children or that she is capable of protecting them from persons with whom she associates.” As to the children’s best interests, the court found that while she has a “strong bond with her children and visits with them went well, [they] indicated that they did not want to return home to her.” In addition, she “has begun experiencing blackouts, seizures, and auditory and visual hallucinations during which she hears voices and sees shadowy figures. The trial court expressed concern regarding whether [she] is able to care for her own needs, much less her needs in addition to those of her children.”