in Re Stewart Minors, 334068

Children removed in Sept 2014 after newborn tested positive for cocaine, methadone, and opiates; petition alleged parental substance abuse and frequent incarcerations.
Father was on parole for felony retail fraud and had ongoing substance-abuse problems; parents ordered to follow a treatment plan.
From Sept 2014–Jan 2015 father attended some counseling and worked but missed many random drug tests; he was jailed Jan–May 2015 after a positive drug screen.
Father repeatedly failed to provide consecutive clean drug screens required for unsupervised visits; visitations were suspended (Oct 2015) and he was later convicted of first-degree retail fraud (Feb 2016).
Psychological evaluation found father presented a severe risk of harm because of substance abuse and personality structure; children were in foster care ~21 months when parental rights were terminated (June 2016).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory grounds for termination existed under MCL 712A.19b(3)(c)(i), (g), (j)	Petitioners argued father failed to remedy conditions, could not provide proper care, and return would harm children	Father did not contest statutory findings on appeal	Court found ample evidence supporting statutory grounds (failure to address substance abuse/criminality, inability to care for children)
Whether termination was in children’s best interests	Petitioners argued children needed permanency, stability, and father was unlikely to provide safe home imminently	Father argued he had recognized harm from substance abuse and implied reunification remained possible	Court held termination did not clearly err: children had limited contact with father, long time in care, and father was unlikely to provide safe, stable home within foreseeable future

In re McIntyre, 192 Mich. App. 47 (1991) (standard for proving statutory grounds by clear and convincing evidence)
In re Trejo, 462 Mich. 341 (2000) (trial-court review and best-interests analysis; primary beneficiary is the child)
In re Terry, 240 Mich. App. 14 (2000) (standard for clear-error review)
In re Olive/Metts Minors, 297 Mich. App. 35 (2012) (factors for best-interest determination: bond, parenting ability, need for permanency)
In re Frey, 297 Mich. App. 242 (2012) (consideration of time in foster care and whether return is likely in foreseeable future)