Termination under MCL 712A.19b(3)(c)(i); Continuing conditions; In re Jackish/Stamm-Jackish; Housing & financial instability; Children’s best interests; Foster placement benefits; Individualized findings; In re White

The court held that § (c)(i) supported termination of respondents-parents’ rights based on their continuing housing and financial instability, and that termination was in the children’s best interests. The children were removed after years of concerns involving homelessness, financial instability, and unmet needs. Respondents later obtained housing but remained thousands of dollars behind on rent, lacked stable income, and continued to spend limited resources on drugs and pets. On appeal, the court agreed that the trial court improperly considered domestic violence, substance abuse, and mental-health concerns under § (c)(i) because those matters “were not among the ‘conditions that led to the adjudication.’” But the error was harmless because “the conditions to which respondents did plead—housing and financial instability—still existed and were unlikely to be rectified in a reasonable time.” Considering their unstable housing, lack of savings, longstanding employment problems, and inability to meet basic financial obligations, the court held that “the trial court did not clearly err by finding statutory grounds for termination existed under” § (c)(i). As to best interests, the court held that “the evidence overwhelmingly supported” termination because the foster parents provided “love, safety, stability, and discipline,” met the children’s behavioral, educational, and medical needs, and intended to adopt all four children. The court also rejected respondents’ individualized-findings argument because the children “were not differently situated” and the trial court nevertheless addressed each child individually. Affirmed.