Termination under §§ 19b(3)(c)(i), (c)(ii), (g), & (j); Children’s best interests; MCL 712A.19b(5); In re Beck; Individualized best-interests findings; In re Olive/Metts

The court held that §§ (c)(i), (c)(ii), (g), and (j) were met, and that termination was in the children’s best interests. The case began after the home was found unsanitary with trash, feces, and drugs present and amid domestic-violence concerns. On appeal, as to § (c)(i), the court found that “under the circumstances, the trial court did not err by finding that respondent[-father] failed to rectify the condition of domestic violence and was not reasonably likely to do so within a reasonable time.” Next, as to § (c)(ii), it noted that he “had issues with anger management, externalizing blame, minimizing the gravity of situations, and abrasive” communication, and that “psychological examinations resulted in a diagnosis of cannabis-use disorder.” He also “failed to address his mental-health issues that arose during the proceedings even after he was made aware of the issues and afforded an opportunity to address them.” As to § (g), the court deferred to the trial court’s assessment of the father and its determination that he “would not adequately provide for his children.” And as to § (j), the court relied on respondent’s failure to complete or benefit from core services, noting that a “parent’s failure to comply with the terms and conditions of his or her service plan is evidence that the child will be harmed if returned to the parent’s home.” Turning to best interests, the court held that termination served the children’s need for permanency and safety given respondent’s minimal progress and inconsistent parenting. The trial court found the children “needed safety, stability, and permanency,” and the record supported the conclusion that he lacked sufficient parenting skills to move beyond supervised contact. The court also rejected his claim that the trial court was required to make separate, detailed findings for each child, explaining that it considered the children collectively and “as two sets of twins,” and that their interests “did not differ significantly,” even though the twin girls had more of a bond with respondent than the twin boys. The court found no error in the trial court’s consideration of obstacles respondent faced early in the case because the record showed the trial court was aware of those circumstances and still determined that reunification was not realistic within a reasonable time. Affirmed.