The Michigan Court of Appeals has vacated an order terminating the parental rights of a mother who was the victim of domestic violence.

The termination of the mother’s rights under a best interests analysis must be vacated because the trial court did not address the child’s placement with a relative.

In a case where the respondent-mother’s parental rights had been terminated, the COA held that her appeal was not moot, even though the child died while the appeal was pending.