Guardianship; Petition to terminate a limited guardianship under MCL 700.5208(1)(a); Compliance with a limited guardianship placement plan under MCL 700.5209(1); “Substantial compliance”; Best interests determination under MCL 700.5209(2); Powers & duties of a lawyer-guardian ad litem (GAL) under MCL 700.5213(6) & MCL 712A.17d(1)

The court held that the probate court did not err by finding appellee substantially complied with the limited guardianship placement plan under MCL 700.5209(1). The probate court terminated appellant’s limited guardianship of JO, a minor. On appeal, the court rejected her argument that the probate court abused its discretion because appellee (JO’s mother) failed to substantially comply with the limited guardianship placement plan, and terminating the limited guardianship was contrary to JO’s best interests. First, appellee’s failure to comply with the weekly visitation requirement was due in large part to the distance between her home and appellant’s, and despite this she consistently visited JO throughout the limited guardianship. She also maintained stable, income-based housing, car insurance, and Medicaid benefits for herself and her children, and although she “lost her job shortly before the hearing regarding her termination petition, she maintained stable employment throughout much of the limited guardianship.” Second, the probate court was not required to determine whether terminating the limited guardianship would serve JO’s best interests. And third, the GAL fulfilled his obligation under MCL 700.5213(6) by: (1) preparing and filing a written report based on his correspondence with the parties, (2) obtaining proof of appellee’s income, housing, and car insurance, (3) evaluating JO’s needs based on his age and stage of development, and (4) recommending “that the probate court terminate the limited guardianship in light of his investigation.” Affirmed.