Procedural due process; Notice & service of process; MCR 3.920(D)(3)(b); MCL 712A.19b(2)(c); MCR 3.977(C)(1); MCL 712A.12; MCR 3.920(B)(2)(b) & (B)(4)(a); Alternate service; MCR 3.920(B)(4)(b); MCL 712A.13; Effect of failing to challenge one of the cited statutory grounds for termination; Child’s best interests; Findings of fact & conclusion of law; MCR .977(I)(1)

The court held that respondent-mother’s procedural due process rights were not violated. Further, the trial court made the required findings of fact and conclusions of law as to the child’s (KM) best interests, and the record evidence supported those findings. It also noted that her failure to challenge one of the statutory grounds for termination relied upon by the trial court precluded appellate relief on that issue. Thus, it affirmed the termination order. She asserted “that she did not attend—and was therefore unable to meaningfully participate in—the termination hearing because she received inadequate notice and corresponding service of process of that hearing[.]” But the court concluded it was “readily apparent that respondent was provided written notice of the new date of the termination hearing within the time frames required by statute and court rule.” It also noted that when the trial “court commented on respondent’s absence at the start of the termination hearing, [her] counsel informed [it] that he had spoken to [her] that morning and that respondent ‘knew about the [termination] hearing’ that afternoon. [She] also called her counsel midway through the termination hearing, at which point counsel again confirmed with the [trial] court that respondent knew of the hearing that day, as he had previously told her that she was required to personally appear in court for the termination hearing on that date.” Thus, the court saw “no error in the trial court’s conclusion that respondent was properly notified of the” termination hearing. As to KM’s best interests, many of the trial court’s findings in its written termination order reiterated what it had “announced at the termination hearing.” But it also mentioned several other relevant considerations, including (1) the lack of any real parent-child bond; “(2) that as KM got older, he consistently expressed that he did not want to enter the visiting room during parenting times with respondent;” (3) that he was closely bonded to his foster parents; and (4) that they wished to adopt him. The court further noted that there was “a significant amount of testimony . . . that respondent failed to participate in or benefit from her case service plan, and alcohol abuse, parenting skills, stable housing, and mental health all remained issues for” her.