In re K. T. McGee, Minor

Summary

The Michigan Court of Appeals affirmed the termination of a respondent mother's parental rights to her minor child under MCL 712A.19b(3)(c)(i), (c)(ii), and (j). The court rejected the respondent's procedural due-process challenge, concluding that she received adequate notice and service of the rescheduled termination hearing. The court also upheld the statutory-grounds and best-interests determinations based on the respondent's continued substance abuse, limited participation in services and parenting time, and the child's bond with his foster parents.

Holdings

1. Respondent received adequate notice and service of the January 29, 2025 termination hearing, and her procedural due-process rights were not violated.
2. Appellate relief was unavailable because respondent did not challenge the trial court's finding under MCL 712A.19b(3)(j), and only one statutory ground is required to terminate parental rights.
3. The trial court did not clearly err in finding that termination was in KM's best interests and made the findings of fact and conclusions of law required by statute and court rule.

Questions Presented

1. Whether respondent received constitutionally adequate notice and service of process of the termination hearing.
2. Whether the trial court clearly erred by finding statutory grounds for termination under MCL 712A.19b(3)(c)(i) and (c)(ii).
3. Whether the trial court clearly erred by finding that termination of respondent's parental rights was in KM's best interests.

Disposition

affirmed