Minor guardianship; Petition to terminate guardianship; Court-structured plan; MCL 700.5209(2)(b)(ii) & (iii); Continued guardianship; MCL 700.5209(2)(c); Best interests; MCL 700.5101(a); Parental care, love, guidance & attention; Substantial disruption of parent-child relationship; Fundamental parental rights; Due process; In re Versalle Guardianship; Statement of factual findings & conclusions; In re Williams; Rittershaus v Rittershaus

The court held that the probate court did not err in finding appellants-parents failed to substantially comply with the court-structured plan, but erred by continuing the guardianship without making the factual findings required by MCL 700.5209(2)(c). The minor was placed in a full guardianship with his maternal grandparents after the mother’s mental-health hospitalization. The probate court later entered a court-structured reunification plan requiring, among other things, the father’s compliance with probation and domestic-violence programming and mother’s continued mental-health stability. On appeal, the court upheld the noncompliance findings, concluding the father failed to complete the domestic-violence program, failed to provide probation reports or releases, and had not shown meaningful behavioral progress, while the mother did not provide sufficient evidence she was stable and compliant with treatment. The court summarized that appellants had “not demonstrated that the probate court” erred as to noncompliance. But the court vacated the continuation order because the probate court’s order merely stated that continuing the guardianship was in the child’s best interests and “did not make any reviewable findings of fact regarding the requirements of MCL 700.5209(2)(c).” The court directed that, on remand, the probate court must address the statutory requirements and “the best-interest factors under MCL 700.5101(a)” using current information. Vacated and remanded.