In re Gilliam Minors — Relative Placement with Biological Father Requires Explicit Best-Interest Analysis Before Termination
The Michigan Court of Appeals affirmed termination of a mother’s parental rights to her youngest child but vacated the termination as to the oldest child, holding that the trial court failed to expressly consider the oldest child’s relative placement with her biological father—an explicit statutory factor that weighs against termination and must be addressed on the record before a best-interest determination can stand.