In Re O L Edie Minor, 367329

The case involves the minor O.L.E., whose mother has a long history of substance abuse and prior terminations of parental rights regarding her other children.
The trial court previously denied a petition to terminate the mother’s parental rights, focusing primarily on her recent improvements and her bond with O.L.E.
O.L.E. had been in out-of-home care for nearly three years, including time in foster care and with relatives.
The mother has a documented history with Child Protective Services stretching over a decade, including multiple terminations based on substance abuse and children born drug-positive.
The concurring opinion highlights that the best-interest analysis should be centered on the child and not the parent, especially in protracted cases with histories of instability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of termination of parental rights is appealable as of right	Argued it should be immediately appealable	Agreed with majority that it is not appealable as of right	Not appealable as of right
Proper focus of the best-interest analysis	Should focus on parent’s bond and recent compliance	Should focus on child’s needs, history, and permanency	Analysis must be child-focused, not parent-focused
Consideration of mother’s recent improvements	Recent improvements justify denying termination	Long history of instability outweighs recent compliance	Court must weigh entire history, not just recent improvement
Impact of current placement with father on need for termination	Placement with father makes termination unnecessary	Placement does not preclude termination if in child’s best interest	Termination can still be in child’s best interest regardless of current placement

In re Olive/Metts Minors, 297 Mich App 35 (trial court must consider child’s best interests, including placement with relatives, when deciding termination of parental rights)
In re White, 303 Mich App 701 (parent’s compliance, visitation history, and child’s well-being during care are relevant to best interests)
In re Jones, 286 Mich App 126 (parent’s history and the length of time a child has been out of care are critical factors)
In re Schadler, 315 Mich App 406 (best-interest determination should focus on the child, not the parent)
In re Moss, 301 Mich App 76 (statute’s history confirms focus on child at best-interest stage)
In re Gonzales/Martinez, 310 Mich App 426 (placement with relatives weighs against, but does not preclude, termination)