in Re J R Bell-Smith Minor, 338019

Child (female) was five when, after a 3–5 day visit with respondent (her father), she immediately told her grandmother that respondent had sexually assaulted her; mother and forensic interviewer heard consistent statements.
Forensic interview was video recorded; interviewer followed protocol and testified to the child’s understanding of truth/lie distinctions.
Initial trial court admitted the DVD statements at adjudication and terminated respondent’s rights; this Court reversed and remanded because the court admitted the DVD itself and combined adjudicative/dispositional proceedings.
On remand a new judge held a proper tender-years hearing, admitted the child’s statements through the forensic interviewer, and conducted separate adjudicative and dispositional hearings; the child testified behind a screen, appeared scared, and partially corroborated prior statements.
Trial court found statutory grounds under MCL 712A.19b(3)(b)(i), (g), and (j) and that termination was in the child’s best interests; this appeal challenges those findings.

Issue	Petitioner (State) / Mother	Respondent (Bell‑Smith)	Held
Whether clear and convincing evidence supports termination under § 19b(3)(b)(i) (parent caused sexual abuse and future risk)	Child’s forensic interview, mother’s corroboration, child’s fear show sexual abuse by respondent and future risk	Denies abuse; claims mother/grandmother coached child and child lied	Affirmed: evidence supports (b)(i) termination
Whether § 19b(3)(g) (failure to provide proper care/custody) is established	Sexual assault shows failure to provide proper care and no reasonable expectation respondent can provide care	Denies allegations; disputes failure finding	Affirmed: sexual abuse demonstrates failure and no reasonable expectation of future care
Whether § 19b(3)(j) (reasonable likelihood of future harm) is established	Child’s consistent reports, fear, and respondent’s conduct/capacity make future harm likely	Denies allegations; points to positive parent–child interactions	Affirmed: reasonable likelihood of future harm found
Whether termination is in child’s best interests	Child’s ongoing fear, need for safety/permanency, corroborated abuse reports favor termination	Argues lack of services and denies abuse; contends bond and parenting ability	Affirmed: trial court did not clearly err in best‑interests determination

In re Mason, 486 Mich. 142 (2010) (standard of review for termination grounds: clear and convincing)
In re LaFrance Minors, 306 Mich. App. 713 (2014) (review of best‑interests determination)
In re JK, 468 Mich. 202 (2003) (definition of clearly erroneous)
In re VanDalen, 293 Mich. App. 120 (2011) (only one statutory ground required to terminate)
In re Ellis, 294 Mich. App. 30 (2011) (same principle: single ground suffices)
In re Terry, 240 Mich. App. 14 (2000) (reunification services not always required)
In re HRC, 286 Mich. App. 444 (2009) (when DHHS seeks termination, services need not be provided)
In re Moss, 301 Mich. App. 76 (2013) (benchmarks and burden for best‑interests finding)
In re White, 303 Mich. App. 701 (2014) (factors for best‑interests analysis)
In re Johnson, 305 Mich. App. 328 (2014) (standard of review for best‑interests)
In re Williams, 286 Mich. App. 253 (2009) (clarifies meaning of clearly erroneous in parental‑rights cases)