COA 379319 IN RE PIETROWSKI MINORS Opinion - Per Curiam - Unpublished 9/23/2026

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
-1-
S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
UNPUBLISHED
September 23, 2026
1:39 PM
In re PIETROWSKI, Minors.
Nos. 379319; 379320
Roscommon Circuit Court
Family Division
LC No. 23-726596-NA
Before: WALLACE, P.J., and CAMERON and KOROBKIN, JJ.
PER CURIAM.
In Docket No. 379319 of these consolidated appeals,1 respondent-mother appeals by right
the trial court’s order terminating her parental rights to her children, PP, EP, IP, and AP, under
MCL 712A.19b(3)(c)(i) (conditions that led to adjudication continue to exist) and (g) (failure to
provide care and custody). In Docket No. 379320, respondent-father appeals by right the trial
court’s order terminating his parental rights to EP, IP, and AP under the same statutory provisions.
We affirm.
I. FACTUAL AND PROCEDURAL BACKGROUND
Respondents had a history of Children’s Protective Services (CPS) investigations as a
result of their ongoing struggles with homelessness, financial instability, and neglect of their
children’s medical, dental, supervisory, and behavioral needs. Respondent-father failed to
maintain steady employment, while respondent-mother struggled to follow through with securing
disability income. Despite extensive efforts by CPS and petitioner, the Michigan Department of
Health and Human Services (DHHS), to assist respondents with their ongoing housing and
financial issues, respondents failed to make any meaningful progress. DHHS therefore petitioned
1 In re Pietrowski Minors, unpublished order of the Court of Appeals, entered February 17, 2026
(Docket Nos. 379319 and 379320).

-- 1 of 5 --

-2-
to remove the children from respondents’ care. The petition also noted concerns regarding
respondents’ mental health, substance abuse, domestic violence, and poor parenting skills.
The trial court authorized the petition, removed the children from respondents’ care and
placed them with a foster family. Although respondents obtained housing almost immediately
after the children were removed, the trial court later assumed jurisdiction over the children after
respondents pleaded to the allegations in the petition regarding their homelessness and financial
instability.
By the time of the termination hearing, respondents were thousands of dollars behind on
their rent. They had avoided eviction only because their landlord at the time, who had since listed
the house for sale, was a family friend. Respondents also failed to achieve a stable income, and,
despite operating at a deficit, chose to spend their limited resources on drugs and acquiring pets.
The trial court found that respondents had failed to sufficiently address their housing and financial
problems and found that termination was in the children’s best interests Accordingly, the trial
court terminated their parental rights as noted. These appeals followed.
II. STANDARDS OF REVIEW
We review the trial court’s factual findings and ultimate determinations of statutory
grounds and whether termination is in the child’s best interests for clear error. In re White, 303
Mich App 701, 709, 713; 846 NW2d 61 (2014). “The trial court’s factual findings are clearly
erroneous if the evidence supports them, but we are definitely and firmly convinced that it made a
mistake.” Id. at 709-710. “A reviewing court must defer to the special ability of the trial court to
judge the credibility of witnesses.” In re LaFrance, 306 Mich App 713, 723; 858 NW2d 143
(2014).
III. STATUTORY GROUNDS
Respondents argue that the trial court erred by finding statutory grounds to terminate their
parental rights. We disagree.
“To terminate parental rights, the trial court must find that at least one of the statutory
grounds for termination in MCL 712A.19b(3) has been proved by clear and convincing evidence.”
In re Ellis, 294 Mich App 30, 32; 817 NW2d 111 (2011). In this case, the trial court found statutory
grounds for termination of both respondents’ parental rights under MCL 712A.19b(3)(c)(i) and
(g). MCL 712A.19b(3)(c)(i) provides:
(3) The court may terminate a parent’s parental rights to a child if the court
finds, by clear and convincing evidence, 1 or more of the following:
* * *
(c) The parent was a respondent in a proceeding brought under this chapter,
182 or more days have elapsed since the issuance of an initial dispositional order,
and the court, by clear and convincing evidence, finds either of the following:

-- 2 of 5 --

-3-
(i) The conditions that led to the adjudication continue to exist and there is
no reasonable likelihood that the conditions will be rectified within a reasonable
time considering the child’s age.
“Even if conditions improved in the months before the termination hearing, a trial court may look
to the totality of the evidence to determine whether a parent accomplished meaningful change in
the conditions that led to adjudication.” In re Jackish/Stamm-Jackish, 340 Mich App 326, 334;
985 NW2d 912 (2022).
It is undisputed that more than 182 days had elapsed between the initial disposition order
and the termination of respondents’ parental rights. Respondents instead argue that the trial court
erred in terminating their parental rights under MCL 712A.19b(3)(c)(i) because it considered
factors beyond the reasons for their adjudication. Respondents pleaded to the allegations that they
were homeless and unable to maintain their financial obligations. The trial court nevertheless
relied, in part, on respondents’ domestic violence, substance abuse, and mental health issues when
terminating their parental rights. Although these issues were concerns throughout the case, they
were not among the “conditions that led to the adjudication” under MCL 712A.19b(3)(c)(i). The
trial court, therefore, erred to the extent that it relied on respondents’ failure to rectify those
conditions as a basis for termination. Nevertheless, we conclude this error is harmless because the
trial court did not clearly err by finding that the conditions to which respondents did plead—
housing and financial instability—still existed and were unlikely to be rectified in a reasonable
time.
The record establishes that respondents were thousands of dollars behind on their rent and
had avoided eviction only because of the personal goodwill of their landlord. Moreover, the
landlord recently sold the home respondents were renting, leaving respondents’ continued
occupancy uncertain. Thus, although respondents were no longer homeless at the time of the
termination hearing, their housing situation was unstable. Their financial circumstances were also
unstable. Respondents had no savings and had not made a full rent payment in over two years.
Instead, respondents used what little money they did have to purchase drugs and pets that they
could not afford to maintain. Their financial resources were so strained that they could not afford
gas for their family vehicle or a $47 prescription for respondent-father.
Respondent-father was employed at the time of the termination hearing, and respondent-
mother was pursuing an appeal of the denial of her disability benefits. But the record showed that
respondents had a history of not being able to hold employment for significant periods, and of
failing to provide the documentation necessary to secure financial assistance. Considering the
totality of the evidence, the trial court did not clearly err by finding statutory grounds for
termination existed under MCL 712A.19b(3)(c)(i).2
2 Because “[o]nly one statutory ground need be established by clear and convincing evidence to
terminate a respondent’s parental rights,” In re Ellis, 294 Mich App at 32, we need not address
whether termination was proper under MCL 712A.19b(3)(g).

-- 3 of 5 --

-4-
IV. BEST INTERESTS
Respondents also argue that termination was not in their children’s best interests. Again,
we disagree.
“If the court finds that there are grounds for termination of parental rights and that
termination of parental rights is in the child’s best interests, the court shall order termination of
parental rights[.]” In re Olive/Metts, 297 Mich App 35, 42; 823 NW2d 144, quoting
MCL 712A.19b(5). “Best interests are determined on the basis of the preponderance of the
evidence.” In re LaFrance, 306 Mich App at 733. “The focus at the best-interest stage has always
been on the child, not the parent.” In re Atchley, 341 Mich App 332, 346; 990 NW2d 685 (2022)
(quotation marks and citation omitted). “The trial court should weigh all the evidence available to
determine the [child’s] best interests.” In re White, 303 Mich App at 713.
To determine whether termination of parental rights is in a child’s best interests, the
court should consider a wide variety of factors that may include the child’s bond to
the parent, the parent’s parenting ability, the child’s need for permanency, stability,
and finality, and the advantages of a foster home over the parent’s home. The trial
court may also consider a parent’s history of domestic violence, the parent’s
compliance with his or her case service plan, the parent’s visitation history with the
child, the children’s well-being while in care, and the possibility of adoption. [Id. at
713-714 (quotation marks and citations omitted).]
Respondents first argue that the trial court improperly weighed the relative benefits of the
children’s foster placement. But those advantages are proper considerations at the best-interest
stage. Id. at 714; In re Olive/Metts Minors, 297 Mich App at 41-42. Respondents also argue that
the trial court failed to address each child individually. The trial court, however, had to make
independent factual findings for each child only to the extent they were differently situated. In re
White, 303 Mich App at 715-716. Here, the trial court appropriately observed that the children
were not differently situated because they were placed together and their foster parents intended
to adopt all four of them. Furthermore, the record reflects that the trial court did, in fact, address
each child individually. Thus, respondents’ arguments lack merit.
Moreover, the evidence overwhelmingly supported the trial court’s best-interests
determination. The children’s foster parents provided the children with love, safety, stability, and
discipline that they had never known with respondents. They ensured that the children’s
behavioral, educational, and medical needs were being met, and were willing to adopt the children.
Although the trial court recognized that there was bond between the children and respondents, it
also found that the children were equally bonded to the foster parents. Compared to the foster
family, respondents could not adequately provide for their children. The children had severe
behavioral and health issues while in respondents’ care, and respondents’ failure to rectify most of
their barriers toward reunification demonstrated a high likelihood that the children would suffer
further harm if returned. Furthermore, despite receiving parenting education services, respondents
struggled to appropriately parent their children during supervised visits. Accordingly, the trial
court did not clearly err by finding that termination was in the children’s best interests.

-- 4 of 5 --

-5-
Affirmed.
/s/ Randy J. Wallace
/s/ Thomas C. Cameron
/s/ Daniel S. Korobkin

-- 5 of 5 --