Stepparent adoption; Termination of parental rights under MCL 710.51(6) of the Michigan Adoption Code; In re NRC; Personal jurisdiction; MCL 600.701(1) & (2)

The court held that the trial court properly: (1) denied respondent-biological father’s motion for summary disposition because general personal jurisdiction over him was satisfied under the first two sections of MCL 600.701, and (2) terminated his parental rights. Petitioners-biological mother and stepfather initiated adoption proceedings asking the trial court to terminate respondent’s parental rights and allow the stepfather to adopt the child. On appeal, the court rejected respondent’s argument that the trial court failed to prove it could exercise personal jurisdiction over him with respect to the adoption and termination proceedings. First, he “did not support his motion for summary disposition with documentary evidence, merely stating that he was moving to dismiss ‘for lack of personal jurisdiction.’ Nor did he provide any documentary evidence in his reply. Instead, [he] asserted he was ‘domiciled in the Kingdom of God’ at the time the petition was filed, and that ‘any current or past use of an address or zip code ha[d] no [e]ffect whatsoever on [his] sovereign status.’ These unsupported statements are insufficient to overcome petitioners’ allegations.” Further, he “attended the hearing on petitioners’ motion for alternative service in person, highly suggesting that he was present in the state at the time process was served, which satisfies MCL 600.701(1).” Moreover, although he “claimed he was ‘domiciled in the Kingdom of God,’ he did not deny residing at” an address where petitioners attempted to serve him, “asserting that his ‘current or past use of an address or zip code’ had no bearing on his domicile.” The court also rejected his claim that the trial court erred by terminating his parental rights, concluding “the threshold requirements of MCL 710.51(6)” were met. Given his noncompliance with the child-support order, the trial court did not err by finding “his one-time payment did not amount to ‘a considerable quantity of the payments required by the order.’” As such, it “properly determined that MCL 710.51(6)(a) was satisfied by clear and convincing evidence.” Further, his only communication with the child “was to send him a calendar and ‘possibly one or two’ other things in the mail.” And he made no “attempt to reinstate parenting time with [the child], a process that was provided for and outlined in the judgment of divorce. Because [he] regularly and substantially failed to contact or communicate with [the child], despite having the ability to do so, the trial court properly determined that MCL 710.51(6)(b) was satisfied.” Affirmed.