in Re jernagin/barnes/mason/bright Minors, 335590

Background

Respondent S. Jernagin appealed termination of her parental rights to five youngest children; she did not contest statutory grounds but challenged best-interest finding.
Children had been in care for nearly three years; four of five had special medical/educational needs.
Psychologist found respondent exhibited symptoms consistent with psychosis and likely could not achieve stability without consistent mental-health treatment; respondent inconsistently attended therapy and sometimes did not take prescribed medication.
Despite services (including a parenting class), respondent’s parenting remained deficient: visits were chaotic, she could not control or redirect children, and some visits were suspended or supervised due to incidents.
Children’s behavior and functioning improved in stable foster placements; foster parents indicated willingness to adopt; visits with respondent sometimes caused regression.
Two children were placed with relatives, but relationship between respondent and relatives had deteriorated, undermining guardianship/cooperation alternative.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was in children’s best interests	Agency/children argued termination was appropriate due to respondent’s ongoing mental-health issues, inadequate parenting, children's need for stability, and benefits of foster/adoptive homes	Jernagin argued termination was not in children’s best interests, contending the court failed to adequately consider relative placements (WB, D’JD) and did not address WB individually	Court held termination was in children’s best interests; no clear error — respondent’s mental health and parenting deficits, children’s improvement in foster care, and damaged relations with relatives supported termination
Whether the court adequately considered WB’s distinct interests	Agency: WB’s interests aligned with siblings — need for permanency/stability; court addressed her situation	Jernagin: Court failed to address WB individually	Court found WB’s interests did not significantly differ and expressly considered her age, time in care, relative placement, and lack of bonding with respondent
Whether relative placement precluded termination	Respondent argued relative placement of two children weighed against termination	Agency argued relative placement was considered but not dispositive given respondent’s hostility and inability to cooperate with relatives	Court recognized relative placements but concluded termination remained appropriate because guardianship was not viable due to deteriorated relationships
Whether trial court considered statutory and evidentiary factors properly	Agency relied on evidence of therapy noncompliance, parenting failures, special needs, and children’s preference/stability	Jernagin argued trial court overlooked mitigating factors	Court applied best-interest factors (bonds, parenting ability, need for permanency, advantages of foster home), considered psychologist and foster testimony, and did not clearly err

Key Cases Cited

In re Moss, 301 Mich. App. 76 (discussing burden of proof for best-interest determination)
In re Olive/Metts, 297 Mich. App. 35 (factors for best-interest analysis and treatment of relative placements)
In re Jones, 286 Mich. App. 126 (additional factors: psychological evaluations, age, domestic violence, history)
In re White, 303 Mich. App. 701 (requirement to address siblings’ differing interests if they significantly differ)