In re Ellis, 294 Mich. App. 30

CPS investigated a complaint after A. Ellis, age under two months, was brought to hospital with severe injuries including skull fractures and internal bleeding.
Medical evidence showed 13 broken bones, including multiple rib fractures and fractures to an arm and legs, consistent with nonaccidental trauma.
Respondents were the child’s sole caretakers with no plausible explanation for the injuries.
A physician expert concluded abuse head trauma and physical abuse; injuries were not accidental, genetic, or related to childbirth.
Trial court terminated respondents’ parental rights under multiple statutory grounds (b( i)(ii), j, k(iii)) after finding clear and convincing evidence and that termination was in the child’s best interests.
Court reaffirmed that it need not determine which parent caused the abuse so long as the evidence shows the parents failed to protect the child.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was proper under MCL 712A.19b(3) grounds.	Powers	Powers	Yes; grounds met by clear and convincing evidence.
Whether lack of pinpointing the perpetrator defeats termination.	Powers	Powers	No; absence of identified perpetrator does not negate termination when parents failed to protect.
Whether termination was in the child’s best interests.	Powers	Powers	Yes; multiple nonaccidental injuries and sole-caretaker parents support best interests.
Whether appellate review of factual findings was properly applied.	Powers	Powers	Standard of review upheld; findings not clearly erroneous.

In re Trejo Minors, 462 Mich 341 (2000) (clear and convincing evidence supports termination; one ground suffices when proper)
In re Powers Minors, 244 Mich App 111 (2000) (termination proper even if multiple grounds; best interests shown)
In re Miller, 433 Mich 331 (1989) (clear error standard; credibility of witnesses weighed in trial court)
In re VanDalen, 293 Mich App 120 (2011) (supports termination where multiple injuries show pattern of abuse by caregivers)