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IN RE OLIVIA DRAPER MINOR
State: Michigan
Court: Court of Appeals
Docket No: 286131
Case Date: 12/23/2008
Preview:STATE OF MICHIGAN
COURT OF APPEALS

In the Matter of OLIVIA DRAPER, Minor.

DEPARTMENT OF HUMAN SERVICES, Petitioner-Appellee, v JENNIFER ZELMER, Respondent-Appellant, and CHARLES DRAPER, Respondent.

UNPUBLISHED December 23, 2008

No. 286131 Berrien Circuit Court Family Division LC No. 07-000100-NA

Before: Murray, P.J., and Markey and Wilder, JJ. MEMORANDUM. Respondent Jennifer Zelmer appeals by right from a circuit court order terminating her parental rights to the minor child pursuant to MCL 712A.19b(3)(c)(i) and (g). We affirm. The trial court did not clearly err in finding that the statutory grounds for termination were established by clear and convincing evidence. MCR 3.977(G); In re Archer, 277 Mich App 71, 73; 744 NW2d 1 (2007). Respondent had a serious drug abuse problem that led to an older child's becoming a court ward in 2004. Respondent continued to use drugs, and the child in this case tested positive for cocaine at birth. Respondent made little effort to comply with the service plan until December 2007, but she then abandoned all efforts to comply with services by midMarch 2008. Petitioner was not required to prove that respondent would neglect her child for the longterm future as held in Fritts v Krugh, 354 Mich 97, 114; 92 NW2d 604 (1958), overruled on other grounds by In re Hatcher, 443 Mich 426, 444; 505 NW2d 834 (1993). Fritts predates the enactment of
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