Stepparent adoption; Child support during the two-year “lookback” period under MCL 710.51(6)(a); MCL 710.51(6)(b); “Substantial” contact under MCL 710.51(6)(b)

Concluding that (1) in light of defendant-father’s (Saintclair) “limited ability to manage his money and his efforts to ensure that [the child] MSL had health-insurance coverage, the trial court did not clearly err by finding that he provided regular and substantial support for MSL based on his overall income, finances, and ability to support the child while incarcerated[,]” and (2) “the trial court properly determined that Saintclair did not regularly and substantially fail to contact MSL under MCL 710.51(6)(b)[,]” the court affirmed. Petitioners argued that the trial court erred by finding that Saintclair “provided regular and substantial support for MSL under MCL 710.51(6)(a).” They also argued “that Saintclair failed to ‘regularly and substantially’ ‘visit, contact, or communicate’ with MSL under MCL 710.51(6)(b).” The court noted that because “MCL 710.51(6) requires that both subsection (a) (lack of financial support) and subsection (b) (lack of contact) be satisfied before a court may terminate parental rights, and the trial court did not clearly err by finding that Saintclair provided regular and substantial support for MSL,” it did not “need not address petitioners’ argument that Saintclair regularly and substantially failed to maintain contact with MSL under MCL 710.51(6)(b).” It also noted, however, that, contrary to petitioner-mother’s testimony, phone records showed that Saintclair telephoned [her] at least 100 times, or roughly four or five times per month, during the two-year lookback period.”