Termination of parental rights; Best interests; In re Moss; In re White; In re CJM; Substance abuse; Meth; Case service plan; Parent-child bond; Relative placement; In re Olive/Metts; In re Atchley; Fictive kin; MCL 712A.13a(1)(j)(i); Guardianship

The court held that the trial court did not err by finding termination of respondent-mother’s parental rights was in the child’s best interests. DHHS became involved after the child was born with meth in his system. Although the mother made progress while incarcerated and initially after release, she relapsed on meth, violated parole, and arrived intoxicated to several parenting-time sessions. On appeal, the court held that the trial court properly weighed her substance-abuse barrier because her “ongoing addiction issues affected her parenting abilities, undermined respondent’s compliance with the service plan, and weighed in favor of termination.” The court also rejected her bond argument, holding that the trial court did not err because testimony showed the child did not ask about or talk about her, and the record supported “a lack of a parent-child bond.” As to relative placement, the court recognized that the trial court was “required to expressly consider” that placement as weighing against termination, but held that the order as a whole showed the trial court “considered the relative placement as weighing against” termination and still found termination appropriate. Affirmed.