Termination under §§ 19b(3)(c)(i) & (c)(ii); Waiver & abandonment of appellate arguments; Failure to participate in or benefit from services; Children’s best interests; MCL 712A.19b(5); In re Olive/Metts; Domestic violence; In re White; Relative placement; In re Mason; Children’s need for permanency & stability

Holding that §§ (c)(i) and (c)(ii) were met, and that termination was in the children’s best interests, the court affirmed termination of respondents-parents’ parental rights. The children were removed because of domestic violence, lack of supervision, and deplorable living conditions. On appeal, the court rejected respondent-father’s argument that a statutory ground was not met. As to §§ (c)(i) and (ii), given his documented lack of progress with the services he was provided, and his unaddressed domestic violence, the court was “not left with a definite and firm conviction that the trial court erred when it found no reasonable likelihood existed that the conditions that led to the adjudication would be rectified . . . within a reasonable time considering the children’s ages.” The court also rejected respondent-mother’s argument that a statutory ground was not met. “The barriers that led to adjudication, such as substance abuse, mental health, lack of parenting skills, lack of financial support, and criminal activity continued to exist without a reasonable likelihood that [she] would rectify them considering the children’s ages.” Finally, the court rejected both parents’ argument that the trial court erred by finding termination of their parental rights was in the best interests of their respective children. When considering the “father’s lack of appropriate bond with his children, his lack of progress in his parent-agency agreement, and the children’s need to be in a stable and permanent placement, a preponderance of the evidence in the entire record supported the trial court’s determination that termination of [his] parental rights served the children’s best interests.” As to the mother, when considering her “lack of progress in her parent-agency agreement, her failure to benefit from it, her inappropriate and at times dangerous behavior, and the children’s need to be in a stable and permanent placement, a preponderance of the evidence in the entire record supported the trial court’s determination that termination of [her] parental rights served the children’s best interests.”