Termination under §§ 19b(3)(c)(i), (g), (j) & (k)(ii); Principle that only one statutory ground must be established; In re Ellis; Best interests of the children; MCL 712A.19b(5); In re White

Noting that respondent-father failed to challenge three of the statutory grounds for termination of his parental rights, and that termination was in the children’s best interests, the court affirmed the trial court’s order terminating his rights. His rights were ultimately terminated on the basis of his sexual abuse of one of the children. On appeal, the court rejected his argument that a statutory ground for termination was not met, noting that “[b]ecause only one statutory ground must be established by clear and convincing evidence to terminate parental rights, respondent’s failure to challenge the trial court’s findings under” §§ (c)(i), (j), and (k)(ii) (he only challenged § (g)) precluded appellate relief for this issue. The court also rejected his claim that termination was not in the children’s best interests, noting the record reflected that the trial court considered the needs of each child when making its best-interests determination. It acknowledged the children’s ages and noted that each of them had differing developmental delays and various special needs. In addition, it found respondent “could not provide for any of the children’s needs and that each child’s need for safety, security, and stability outweighed any bond with” him. Further, none of the children ever asked about him, none of them “received the specialized treatment and therapy that they each needed until they were placed in their preadoptive foster homes, and respondent admitted that he had not participated in any parenting classes meant to assist him in caring for any of his children’s needs.” They also “demonstrated significant food insecurity in their foster” homes. Moreover, the child who was sexually abused “continued to demonstrate sexual behaviors that were inappropriate for a child her age, [and] again reported to clinicians and DHHS employees that respondent had sexually abused her[.]” Finally, respondent “was unable to support himself, let alone one or more of his children, given that he struggled to maintain full-time employment for any meaningful period of time, continually relied on money from his family members for basic necessities, and still lived in a one-bedroom motel room—housing he acknowledged was inappropriate for any of his children.”