Termination under § 19b(3)(c)(i); Placement with relatives; Guardianship under MCL 722.875b; Barriers to reunification; Child’s best interests

Concluding that § (c)(i) existed and that the trial court did not err by finding termination was in child-AJD’s best interests, the court affirmed. The initial disposition occurred on 2/15/24 and the trial court terminated respondent-mother’s parental rights on 5/1/25. “The time between these dates exceeds 182 days.” Thus, the first requirement of § (c)(i) was satisfied. According to the petition, her “initial barriers to reunification included her substance use, emotional stability, and unstable housing. Although respondent participated in various forms of substance abuse therapy throughout the case, she tested positive for Xanax twice and for meth[] 17 times. [She] also repeatedly refused to take accountability for her substance abuse, only admitting to using [meth] one time in 2024 and claiming that every other positive drug screen was a false positive.” The trial court did not err by concluding that she “had not addressed her substance abuse issues by the time of termination.” It also did not err by finding that her “emotional instability was still a barrier to reunification.” And it did not err by finding her “unstable housing situation was still a barrier to reunification.” Finally, the trial court did not err by holding “that there was no reasonable likelihood that these conditions would have been rectified within a reasonable time considering the child’s age.” Respondent argued “that the trial court should have given her more time to address her barriers to reunification.” Given her “unstable housing, continued emotional instability, consistent positive drug tests, and refusal to take accountability for her substance use, the trial court did not” err in “finding by clear and convincing evidence that respondent’s barriers to reunification continued to exist.”