Termination under § 19b(3)(b)(i); Child’s best interests; In re White; Parent-child bond; In re Olive/Metts Minors; Physical abuse; In re Schadler; Nonaccidental abusive head trauma (AHT)

Holding that § (b)(i) was met, and that termination was in the child’s best interests, the court affirmed termination of respondent-father’s parental rights. His rights were terminated after a medical exam confirmed the child’s injuries were consistent with AHT rather than an accidental fall from the bed. On appeal, the court rejected his argument that a statutory ground for termination was not met. On the basis of the evidence, including the medical evidence, the court held that the trial court did not err by finding respondent caused the child’s “injuries and there was a reasonable likelihood of injury in the foreseeable future.” Because the child “suffered nonaccidental injuries while in respondent’s care, there was clear and convincing evidence to establish statutory grounds for termination under” § (b)(i). The court also rejected his claim that termination was not in the child’s best interests. The child “suffered serious injuries while in respondent’s care.” And he “was uncooperative with the DHHS investigation by refusing to answer questions regarding” the child’s injuries. His explanation for the “injuries was incongruent with the medical diagnosis. This abuse amounted to aggravating circumstances under MCL 722.638(1) and (2).” Further, respondent did not provide the “DHHS with verification of income, or allow a home assessment.” Meanwhile, the child “was doing well in his placement. He was meeting his developmental milestones and receiving continued medical care.”