In re T.L. Fowler, Minor
Michigan Court of Appeals
2016 WL 6106486 (2016)
- Written by Salina Kennedy, JD
Facts
The State of Michigan (the state) (plaintiff) initiated proceedings to terminate Fowler’s (defendant) parental rights because Fowler had failed to provide adequate housing for his child, his income was inadequate to support his child, and because he used marijuana. While the matter was pending, Fowler obtained employment and suitable housing. Fowler’s marijuana use was the only statutory condition for termination of parental rights that continued to exist at the time of Fowler’s termination hearing. However, Fowler had a valid medical-marijuana card permitting him to use medical marijuana under Michigan law. At Fowler’s termination hearing, witnesses for the state testified that Fowler’s marijuana use presented a risk of harm to his child because (1) the effects of marijuana were unknown, (2) marijuana use was normally illegal, and (3) unsavory people were involved in the business of dealing drugs. The trial court terminated Fowler’s parental rights without making a specific finding concerning whether Fowler’s marijuana use presented an unreasonable danger to his child. Fowler appealed to the Michigan Court of Appeals.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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