In Re a Newnum Minor, 357710

AN born May 2019 tested positive for methamphetamines, amphetamines, and marijuana; petition filed in June 2019 and child placed in foster care.
Respondent admitted untreated mental-health issues and was ordered to complete parenting classes, mental-health therapy, domestic-violence counseling, substance-abuse services, random drug screens, stable housing/employment, and supervised parenting time.
Respondent had intermittent positive drug tests during the case, multiple domestic-violence incidents with AN’s father, and later entered a relationship with a man with a history of substance abuse and terminated parental rights; respondent did not fully disclose that relationship.
AN has special needs (feeding/swallowing issues, occupational therapy) and respondent missed most medical/therapy appointments, attended few OT sessions, and failed to follow up with infant mental-health services; AN showed stress-related symptoms and behavioral changes after visits.
AN was continuously placed with a foster family that provided stability, expressed intent to adopt, and with whom AN was bonded; respondent never had unsupervised parenting time.
Trial court found reasonable reunification efforts were made, concluded statutory grounds under MCL 712A.19b(3)(g) (and additionally (c)(ii) and (j)) were met, and terminated respondent’s parental rights; this Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supported statutory grounds for termination (MCL 712A.19b(3))	Petitioner: respondent’s drug use, ongoing domestic-violence relationships, failure to engage in services, and inability to meet AN’s special needs satisfy statutory grounds—especially (g).	Respondent (Newnum): she made progress, addressed mental-health issues, and trial court erred in finding statutory grounds.	Affirmed. Sufficient evidence supports termination under (g); court also deemed (c)(ii) and (j) supported.
Whether termination was in AN’s best interests	Petitioner: AN needed permanency and stability; respondent’s conduct harmed AN and she failed to progress; foster home provided stable, adoptive placement.	Respondent: bond with AN and asserted parenting improvements meant termination was not in AN’s best interests.	Affirmed. Preponderance of evidence showed termination served AN’s best interests given health/behavioral harm, lack of parental progress, and stable foster placement.

In re VanDalen, 293 Mich App 120 (2011) (termination requires clear and convincing evidence of a statutory ground)
In re LaFrance, 306 Mich App 713 (2014) (standard of review and deference to trial court credibility findings)
In re HRC, 286 Mich App 444 (2009) (if one ground is established, court need not rely on all alleged grounds)
In re White, 303 Mich App 701 (2014) (best-interest determination must be proved by a preponderance of the evidence)
In re Trejo Minors, 462 Mich 341 (2000) (focus on the child in best-interest analysis)
In re Medina, 317 Mich App 219 (2016) (trial court may consider the whole record for best interests)
In re Olive/Metts, 297 Mich App 35 (2012) (parent–child bond is only one factor in best-interest analysis)
In re CR, 250 Mich App 185 (2002) (a disputed or unhealthy bond can support termination)
In re Plump, 294 Mich App 270 (2011) (domestic-violence victim status alone cannot justify termination; parental conduct must be harmful)