Termination of parental rights; Child’s best interests; In re Sanborn; Relative placement; In re Mason; “Relative”; MCL 712A.13a(j); Guardianship; MCL 712A.19a(8); In re Rippy

Holding that termination of respondent-mother’s parental rights was in the child’s best interests, the court affirmed. Her rights were terminated on the basis of improper supervision, as well as her failure to complete services or have contact with the child. On appeal, the court rejected her argument that termination was not in the child’s best interests. The record revealed “the trial court carefully considered the evidence and addressed the relevant factors in making its best-interest finding.” It noted that respondent was offered services, but did not participate in them, and failed to create a safe environment in which the child could live. It also considered the trauma the child had endured because of respondent’s “‘inability to self-regulate.’” And it considered the lack of a parent-child bond. The court next rejected respondent’s claim that the trial court erred by failing to properly consider the child’s placement with a relative. “The trial court acknowledged that [the child] was placed with a relative, but explained that [he] needed permanency.” A woman who may have been fictive kin or a cousin “was interested and able to provide [him] with the permanency he deserves.” He looked to her, “rather than his parents, for love, support, comfort, and protection.” As such, “the trial court properly resolved the issue regarding [the child’s] placement with a relative in making its best-interest finding.” Finally, the court found that respondent did not show “that the trial court erred by failing to explicitly consider guardianship when making its best-interest finding.”