Termination under §§ 19b(3)(c)(i) & (j); Principle that only one statutory ground must be met; In re Moss Minors; Whether there was any meaningful change in the parent’s ability to overcome the circumstances that originally caused adjudication; In re Williams; A parent’s persistent failure to overcome substance abuse despite participation in treatment as grounds for termination; In re Conley; Termination when a parent fails to prevent the child’s exposure to domestic abuse that causes the child harm; In re Plump; Best interests of the children; MCL 712A.19b(5); In re Olive/Metts Minors; In re White; Effect of a parent’s inability to provide stability & permanence for the children; In re L D Rippy; In re Brown/Kindle/Muhammad Minors; Reasonable reunification efforts & a parent’s commensurate responsibility to participate in & benefit from the services offered; In re Frey

Holding that at least one statutory ground was met, that termination was in the children’s best interests, and that the DHHS made reasonable reunification efforts, the court affirmed termination of respondent-mother’s parental rights. Her parental rights were terminated based on her substance abuse and emotional instability, and her abusive relationship with the children’s father. On appeal, the court rejected her argument that the DHHS failed to prove a statutory ground for termination. “At the time of the termination hearing, respondent had not established a lengthy period of sobriety and continued to use substance abuse as a method of coping with other ongoing issues.” In addition, “there was abundant evidence that respondent continued to struggle with domestic violence and was either unwilling or unable to separate herself from the children’s father.” The court also rejected her claim that termination was not in the children’s best interests. “Respondent was almost wholly unable or unwilling to meaningfully comply with her case service plan, demonstrated little benefit from those services that she did participate in, and demonstrated no lasting commitment to doing what was necessary for her children to return to her home. Despite regularly testing positive for cocaine and other drugs, respondent only sparingly participated in substance abuse counseling and treatment and rejected recommendations that she undergo a more intensive treatment program. She also continued to associate with the children’s father, a man who abused her.” Finally, the court rejected her contention that the DHHS failed to provide reasonable reunification efforts. “Despite an initial showing of participation and desire, respondent faltered as time passed and simply did not participate in services that would secure the return of her children to her care. [She] only chose to complete a seven-day drug treatment program and, after relapse, rejected the recommendation that she participate in an intensive 30-day program. She failed to engage in counseling services to learn new methods of coping with stress and loneliness, but resorted to the same behaviors that caused the children to be placed in foster care.”