In the Matter of Atkins (1982)
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In Re Ernst (1983)
In Atkins, the Court held that the "best interest” standard need not apply, but that the proper standard instead is "whether the parent has been shown by clear and convincing evidence to be unfit and unable to become fit within a reasonable period of time”, MCL 712A.19a; MSA 27.3178 (598a); Atkins, supra, p 541, fn 7 .
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In Re Gentry (1985)
In the Matter of Atkins, 112 Mich App 528, 539; 316 NW2d 477 (1982).
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In Re McCombs (1987)
See also In re Atkins, 112 Mich App 528, 542-543 ; 316 NW2d 477 (1982), lv den 413 Mich 912 (1982).