in Re C Russell Minor, 331270

Father appealed termination of his parental rights to minor child; trial court terminated under MCL 712A.19b(3)(c)(i), (c)(ii), (g), and (j).
Child had history of inconsistent caregiving before foster placement; psychologist diagnosed Disinhibited Social Engagement Disorder and noted a developing secure attachment to foster parents.
Father had periods of incarceration, limited contact with DHHS/BCS caseworker, missed many parenting visits, and failed to complete recommended services (substance treatment, psychological follow-up, parenting plan tasks).
Father lived at paternal grandfather’s house for part of the case, had unverifiable employment and housing concerns, and was unsuccessfully discharged from substance counseling for nonattendance.
Agency provided services, gas cards, and attempted placements (father contended agency should have placed child with paternal grandfather and objected to placement with adoptive-seeking foster parents).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict of interest in placement	Father: DHHS/BCS created conflict by not placing child with paternal grandfather and placing him with foster parents who sought adoption	DHHS/BCS: placement decisions were appropriate and services/offers were provided	Court: Issue abandoned for lack of briefing; no plain error shown
Statutory grounds — failure to provide care (MCL 712A.19b(3)(g))	Father: He participated in some services and had housing/work, challenging sufficiency of evidence	DHHS: Father’s incarceration, poor compliance, missed visits, and inappropriate caretakers show failure to provide care and no reasonable expectation of improvement	Court: Sufficient clear-and-convincing evidence to terminate under (g)
Statutory grounds — likelihood of harm if returned (MCL 712A.19b(3)(j))	Father: Challenges use of his record and contends termination unjustified	DHHS: Father’s noncompliance and child’s attachment disorder show reasonable likelihood of emotional/physical harm if returned	Court: Clear-and-convincing evidence supports termination under (j)
Best interests	Father: Argues trial court relied on uncorroborated information and that termination was not in child’s best interest	DHHS: Child’s need for stability, attachment to foster parents, expert testimony, and father’s unresolved issues favor termination	Court: Preponderance of evidence shows termination is in child’s best interests

In re VanDalen, 293 Mich. App. 120 (application of clear-and-convincing standard and review for clear error)
In re HRC, 286 Mich. App. 444 (deference to trial court credibility findings in termination cases)
In re JK, 468 Mich. 202 (parent-agency agreement noncompliance as evidence of failure to provide proper care)
In re White, 303 Mich. App. 701 (service-plan noncompliance evidences likelihood of harm)
In re Moss, 301 Mich. App. 76 (best-interest focus on child and required burden of proof)
In re Olive/Metts, 297 Mich. App. 35 (factors for best-interest determination)
In re Mason, 486 Mich. 142 (limits on terminating solely for incarceration/record)