Termination under § 19b(3)(c)(i); Failure to make any meaningful change; In re Williams; Principle that a parent must both participate in services & demonstrate sufficient benefit from the services; In re Atchley; Best interests of the child; MCL 712A.19b(5); In re Medina; A parent’s substance-abuse history; In re Rippy; The risk of harm to the child if returned to the parent’s care; In re VanDalen; Relative placement; In re Gonzales/Martinez

Holding that § (c)(i) was met, and that termination was in the child’s best interests, the court affirmed termination of respondent-mother’s parental rights. The child was removed after respondent left him in a car during a drive-by shooting while she took shelter. Her rights were later terminated primarily on the basis of her failure to participate in regular drug screens, substance abuse treatment, and individual therapy. On appeal, the court rejected her argument that a statutory ground for termination was not met. “In this case, the record supports the trial court’s finding under [§ (c)(i)] that more than 182 days had elapsed after the issuance of the first dispositional order, the conditions that led to the adjudication continued to exist, and there was no reasonable likelihood that the conditions would be rectified within a reasonable time considering the child’s age.” The court disagreed “that respondent made meaningful progress on her treatment plan. [She] was given almost four years to rectify the issues that led to the adjudication before her parental rights were terminated, but [she] failed to obtain suitable housing, failed to demonstrate regular income, failed to participate in the court-ordered drug screening, failed to address her substance use, failed to benefit from her parenting classes, failed to attend individual therapy, and failed to visit” the child or to provide for the child in any way. “Respondent failed to rectify any of the conditions that led to the adjudication during the nearly four years she was given to rectify those issues.” The court also rejected her claim that termination was not in the child’s best interests. “[R]espondent made no progress in her treatment plan. [She] failed to obtain suitable housing, and therefore failed to provide a stable and permanent home for the child. [Her] untreated drug use also indicates [she] was not progressing in the treatment plan and that termination was in” the child’s best interests. “Respondent also frequently missed visits with the child, which upset” him and caused her bond with him to deteriorate. “By contrast, the willingness of [the child’s] relative caregivers to adopt him weighed in support of termination; almost four years had passed since his removal from respondent’s care, and [he] needed permanence, stability, and finality.” The child’s “success in his placement with his relative caregivers also weighed in support of termination.”