Children’s best interests; MCL 712A.19b(5); Best-interest factors; In re MJC; Anticipatory neglect; In re Mota; Risk of harm; Parent-child bond; Criminal history; CSC I conviction under MCL 750.520b(1)(a); CSC II conviction under MCL 750.520c(1)(a)

The court held that the trial court did not err by finding termination of respondent-father’s parental rights was in the children’s best interests despite his strong bond and appropriate visitation. This case returned after a prior remand requiring findings on statutory grounds and, if applicable, best interests. On remand, the trial court terminated his parental rights based on respondent’s prior CSC convictions involving children and the credible allegation that he sexually assaulted the children’s mother’s 16-year-old niece while the children were asleep in the home. On appeal, respondent challenged only the best-interest ruling. The court held that the trial court properly considered respondent’s bond with the children, completion of services, and consistent visits, but also properly weighed his inability to provide basic care while in rehabilitation and later assisted living. It further held that the trial court could consider his criminal history, including CSC convictions involving minors and the more recent assault of the mother’s niece, because under anticipatory neglect, “how a parent treats one child is probative of how that parent may treat other children.” The court rejected respondent’s argument that the niece was not his child or the children’s sibling, reasoning that “‘abuse is abuse,’” and the record showed a pattern of using proximity to young children related to cohabiting domestic partners to sexually abuse them. Affirmed.