Termination under §§ 19b(3)(c)(i) & (g); In re White; In re Ellis; Principle that only one statutory ground need be established by clear & convincing evidence to terminate a respondent’s parental rights; Child’s best interests; In re Olive/Metts Minors; In re Moss Minors; In re Schadler; In re LE; In re Trejo Minors; In re Gonzales/Martinez; Placement with relatives; In re Mason; Relative defined; MCL 712A.13a(1)(j)
Holding that § (c)(i) was established by clear and convincing evidence, and that termination of respondents-parents’ parental rights was in the child’s (A) best interests, the court affirmed termination of their parental rights. Throughout the proceedings, respondent-mother missed numerous drug screens, and she relapsed in 11/18. She “also missed visitation appointments, even though her attendance did improve at some point during proceedings.” Near the end of the proceedings, the mother “did improve her willingness to avail herself of the services provided to her and achieved a sustained period of sobriety. However, the stability of her recent sobriety remained unpredictable given her recent relapse and long history of substance abuse.” Further, the mother obtained housing, but it was obtained through and paid for by Lutheran Social Services. She remained unemployed at the final termination hearing, and it was unclear how the mother could provide long-term housing for A without a source of income. Respondent-father frequently missed visitations with A. “Some of the missed visits were caused by incarceration, but many were not caused by incarceration.” The father also struggled heavily with substance abuse and experienced a recent relapse in 11/18. He “previously failed to fully avail himself of any of the services offered to rectify his barriers; however, toward the end of the proceedings, respondent-father engaged with his peer recovery coach and made efforts to continue his sobriety.” The father “achieved a sustained period of sobriety shortly before the termination of his parental rights.” But given the father’s “long history of substance abuse, these attempts to achieve and maintain sobriety remained fragile and unpredictable.” Further, he “was unemployed and maintained that he wished to seek only part-time employment. Both respondents resided in the same house, which presented the issue of how” the father could provide a long-term home to A within a reasonable time absent steady employment.
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