Jurisdiction over the children; Postponements of the adjudication; MCR 3.972(A); Motion for a continuance; Due process; Mathews v Eldridge; Mathews balancing test; Termination under §§ 19b(3)(g) & (j); Children’s best interests

The court found that “given that all the postponements occurred with respondent-mother’s approval,” and considering that she did not show that the “erroneous postponements affected the outcome of the proceeding or resulted in a fundamentally unfair proceeding,” the ones that constituted error did not require reversal. The court also held that the trial court did not violate her due-process rights by denying her motion for a continuance. Finally, it concluded that (1) §§ (g) and (j) existed and (2) “the trial court did not clearly err by finding by a preponderance of the evidence that termination of respondents’ parental rights was in the children’s best interests.” The court rejected the mother’s argument as to the denial of a continuance given that proofs were closed and her “presence at the ruling could have no effect on the trial court’s ruling, and considering that continuing the termination proceeding until an unknown time would have created an unwarranted administrative burden[.]” As to statutory grounds for termination, the trial court concluded that § (g) applied to both respondents. The court found that throughout the “case, whether from the effects of substance abuse, mental-health issues, or poor parenting skills, respondents made choices that threatened the emotional well-being of their children. They violated the trial court’s placement order and supervised parenting-time order” by, among other things, absconding with two of the children. The court concluded that at the time of the termination hearing, they “had yet to address any of these issues in a meaningful way.” On this record, the court could not “say that the trial court was ‘more than maybe or probably wrong’ by finding that clear and convincing evidence established [§] (g) as a statutory basis for the termination of respondents’ parental rights.” It also found that some “of these same circumstances established grounds for termination under” § (j). Affirmed.