in Re Taylor Minors
334629
| Mich. Ct. App. | Jul 11, 2017Background
- Respondent father established paternity and was involved in child protective proceedings concerning three special-needs children (MET, MST, MWT).
- The trial court found statutory grounds for termination under MCL 712A.19b based on respondent’s lack of stable housing, sporadic income, incomplete therapy (parenting/anger/domestic-violence), and unresolved anger/violence issues.
- Children were placed with maternal relatives; earlier appellate opinion remanded for the trial court to explicitly address how relative placement affected the best-interest analysis for MET and MST.
- On remand the trial court incorporated prior findings and focused on multiple incidents where respondent lashed out verbally and physically at the children’s relative caregivers and displayed belligerent behavior in court, agency settings, and meetings.
- The court found respondent had not shown lasting improvement over two years, had not completed required services before the termination hearing, and could not reliably meet the children’s ongoing special-needs care or provide permanency and stability.
- The trial court concluded, and the Court of Appeals affirmed, that termination of respondent’s parental rights was in the best interests of MET and MST despite their placement with relatives.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether termination is in children’s best interests given placements with relatives | Petitioner: termination is appropriate; record shows lack of parental improvement, unresolved anger/violence, inability to provide permanency/stability | Respondent: relative placements weigh against termination; respondent bonded with children and argued placement with relatives makes termination unnecessary | Held: Affirmed — termination is in best interests despite relative placement because respondent’s conduct threatened relatives’ ability to care for the children and he failed to complete services |
| Whether the court properly considered relative placement per appellate remand | Petitioner: court adequately addressed effect of relative placement and risk posed by respondent’s behavior | Respondent: court needed to give greater weight to relative placement and stability provided by relatives | Held: Affirmed — court explicitly addressed relative placement and found respondent’s behavior undermined it |
| Whether respondent’s unresolved anger/domestic-violence supports termination | Petitioner: ongoing incidents and altercations with caregivers show risk to children and caregivers, supporting termination | Respondent: argued bond/visitation and some participation in services mitigate against termination | Held: Affirmed — record supports unresolved anger/domestic-violence and its negative impact on caregivers and children’s stability |
| Whether children’s need for permanency and special-needs care favors termination | Petitioner: children require frequent therapy/medical transport and permanency; waiting years for father’s improvement is not in their best interests | Respondent: requested more time to stabilize and complete services | Held: Affirmed — children’s need for prompt permanency and demonstrated lack of parental stability weigh in favor of termination |
Key Cases Cited
- In re White, 303 Mich. App. 701 (discussing best-interest standard and factors)
- In re Moss, 301 Mich. App. 76 (trial court focus should be child, not parent)
- In re Olive/Metts, 297 Mich. App. 35 (factors relevant to best-interest analysis)
- In re Frey, 297 Mich. App. 242 (consideration of length of foster/relative placement and return prospects)
- In re Williams, 286 Mich. App. 253 (standard for determining clear error)