Termination under § 19b(3)(b)(i); Anticipatory neglect; Due process in child protective proceedings; Child’s best interests; In re Olive/Metts Minors; Relative placement; “Relative” under MCL 712A.13a(1)(j); In re Boshell/Shelton

Holding that § (b)(i) supported termination of respondent-father’s parental rights, but that the trial court failed to consider the child’s placement with a relative, the court affirmed as to statutory grounds, vacated as to best interests, and remanded. His parental rights were terminated based on his sexual abuse of the child’s half-sibling, IW. On appeal, the court found clear and convincing evidence that § (b)(i) supported termination of respondent’s parental rights because he sexually abused IW, creating a reasonable likelihood the child would be harmed in the future. It also rejected his due process claim, explaining that the trial court properly allowed questioning related to financial support and parenting because it went to jurisdiction and that respondent was afforded an opportunity to be heard. However, it vacated the best-interest ruling because the trial court failed to address the child’s placement with his mother, a relative under MCL 712A.13a(1)(j). The court reiterated that under Olive/Metts a “trial court’s failure to explicitly address whether termination is appropriate in light of the children’s placement with relatives renders the factual record inadequate to make a best-interest determination.”