Termination; Best interests of the children; MCL 712A.19b(5); In re Gonzales/Martinez; Relative placement; In re Olive/Metts Minors

Holding that termination was in the children’s best interests, the court affirmed termination of respondents-parents’ parental rights. Their rights were terminated on the basis of abuse, poor parenting skills, and improper supervision. On appeal, the court rejected their argument that termination was not in the children’s best interests. As to respondent-mother, it noted that “the trial court’s consideration of the relative placement was sufficient to meet the requirements of Olive/Metts.” It also “did not err in finding that the relative placement was outweighed by other factors favoring termination.” She was not benefiting from her service plan, and “the children were all doing well in their foster placements, which had each agreed to adopt the child in their care.” In addition, the children required extra care and attention that she could not provide. “The trial court did not err in finding that the children’s need for permanency and stability outweighed the relative placement in this case.” As to respondent-father, his substance abuse diminished his parenting skills, which he already lacked, and the children’s “placements offered each child stability, permanency, and finality that [he] could not offer.”