No-contest plea to the statutory grounds for jurisdiction & termination; Principle that the trial court must inform a respondent of the consequences of his or her plea, MCR 3.971(B)(4); In re Pederson; Individualized best-interests determination; In re White; Ineffective assistance for failing to call mothers as witnesses; In re Lovitt; Anticipatory neglect inference; In re Mota

The court held that respondent-father’s challenges to his no-contest pleas, the best-interests determination, and the effectiveness of trial counsel lacked merit and affirmed termination of his parental rights. His rights to his five children were terminated after one of them, SLHP, disclosed sexual abuse. Respondent had entered no-contest pleas to jurisdiction and statutory grounds, which the trial court accepted before conducting a best-interests hearing and terminating his parental rights. On appeal, the court first found that his no-contest pleas were made with “sufficient awareness of the relevant circumstances and likely consequences.” There was no outcome-determinative error. The court also rejected his challenge to the best-interests findings, emphasizing that “[t]he focus of the best-interests inquiry is on the child, not the parent,” that the trial court considered safety, trauma to SLHP, placements with the mothers, permanency and stability, bonds and preferences, and that anticipatory neglect allowed it to infer risk to the siblings. “On this record, the trial court’s individualized findings were adequate, and its best-interests determination was” not erroneous. Finally, the court rejected his ineffective-assistance claim premised on counsel’s failure to call the mothers, finding no factual predicate, reasonable strategy given the evidence and the likelihood some mothers would not support respondent, and no prejudice because he “failed to demonstrate a reasonable probability of a different outcome had the mothers testified directly.” Affirmed.