Background
Michigan’s Department of Health and Human Services began working with the family in 2021 after two older children took a firearm from a neighbor’s home, pointed it at people, and discharged it. Later that year, another child was born testing positive for THC and cocaine. The children initially remained with respondent-mother under agency supervision, but the proceedings expanded amid allegations of incomplete services, substance abuse, domestic violence, inadequate supervision, and unsafe living conditions.
The children were removed in February 2023, briefly returned after the parents showed progress, and removed again after conditions deteriorated. Respondent-father was charged with aggravated domestic violence against respondent-mother, was ordered to have no contact with her, stopped communicating with the agency, and did not see his children after June 2023. Respondent-mother continued to struggle with services, substance screening, parenting visits, and the children’s extensive behavioral and trauma-related needs. After a July 2025 termination hearing, the Oakland Circuit Court terminated respondent-mother’s rights to six children and respondent-father’s rights to three under MCL 712A.19b(3)(c)(i), (g), and (j).
The Court’s Holding
The Michigan Court of Appeals affirmed, holding that the trial court did not clearly err in finding termination to be in each child’s best interests. As to respondent-mother, the court concluded that the trial court individually assessed all six children, including their bonds with her, trauma and behavioral needs, progress in foster care, and need for permanence, stability, safety, and guidance. The record supported findings that the children’s bonds with respondent-mother were unhealthy, diminished, minimal, or nonexistent and that she had not benefited sufficiently from extensive services to meet their needs safely.
As to respondent-father, the court upheld findings that his bonds with the three affected children were minimal, unhealthy, or nonexistent. He had not seen them for more than two years, had not complied with his treatment plan, and had not addressed domestic violence, substance abuse, parenting, housing, or employment concerns. The children were doing well and had healthy attachments in foster placements whose caregivers were willing to adopt. The court also rejected the parents’ reliance on sibling separation, explaining that each child’s individual best interests controlled and that their caretakers could meet needs the parents could not.
Key Takeaways
- A termination court must assess each child’s best interests individually, particularly when the children have different bonds, placements, and trauma-related needs.
- The existence of a parent-child bond does not preclude termination when the bond is unhealthy or the parent cannot provide safety, stability, guidance, and appropriate care.
- Stable housing or employment alone does not outweigh failure to benefit from services, unresolved substance abuse or domestic violence, and an inability to meet children’s significant needs.
Why It Matters
The decision illustrates the child-centered nature of Michigan’s best-interest analysis. Courts may consider the entire record, including the quality rather than merely the existence of parental bonds, compliance with and benefit from services, visitation history, domestic violence, foster-care progress, adoptability, and the need for permanence.
It also confirms that sibling unity, while important, is not dispositive. When siblings have substantial individualized needs, termination may remain appropriate despite separate placements if the evidence shows that their current caretakers can provide the safety and stability their parents cannot.