Best interests; Relative placement; MCL 712A.19b(5); In re Olive/Metts

The court held that the trial court’s finding that it was in the child’s (LG) best interests to terminate respondent-father’s parental rights was not erroneous. “The testimony established that LG was thriving in his mother’s care, that he was getting ready to start kindergarten, that he was confused by the inconsistent phone contact with respondent, that the consistency of future contact was not guaranteed, that respondent posed a psychological risk to LG given his conviction for sexually exploiting LG’s half-siblings, that LG had only ever known one home, and that respondent’s 40-year incarceration would preclude any reunification until long after LG reaches 18 years of age.” The court agreed with respondent that the trial court erred by finding a lack of extended family support because the record showed financial help and contact from LG’s paternal grandfather. But it held that this error did not render the overall best-interests ruling erroneous. It also rejected respondent’s arguments that the trial court failed to consider LG’s placement with his mother, respondent’s parenting ability, and LG’s safety and stability. It held that the trial court adequately addressed LG’s placement with his mother, that respondent’s conduct was “fundamentally at odds with the responsibility of parenthood,” and that his 40-year sentence made any realistic reunification impossible. Affirmed.