Children’s best interests; MCL 712A.19b(5); In re Olive/Metts Minors; Parent-child bond; Permanency & stability; In re White; Relative placement; In re Atchley
The court held that the trial court did not err by finding that termination of respondent-mother’s parental rights was in the children’s best interests. Respondent entered a no-contest plea establishing statutory grounds for termination. The factual basis included domestic violence in the home, respondent’s arrest in the children’s presence for brandishing a firearm, and a prior termination involving four other children after a child’s death. On appeal, respondent challenged only the best-interest finding. The court first held that the record supported termination because respondent visited the children only once, “the day prior to the best-interest hearing,” despite knowing about weekly visits for more than six months and receiving transportation assistance. It also noted that the children “have not developed a bond with respondent due to her prolonged absence,” that respondent did not attend medical appointments or school functions, and that she failed to maintain regular contact with the foster care specialist. The court next held that the children’s need for permanence and stability supported termination because respondent reported living in a home without “electricity and heat,” one child (KLV) needed counseling to address parental absence, and the other two (NME and AAE) had little or no recognition of respondent as their mother. Although KLV and NME were placed with relatives, the court held that relative placement was not dispositive where termination remained in the children’s best interests. Affirmed.
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