Michael J factors in Arizona

2021At bottom, incarceration does not automatically render a parent unfit and DCS “has a responsibility to assist parents, incarcerated or not, who face termination of their rights.” Michael J., 196 Ariz. at 253 ¶ 38 (Zlaket, C.J., concurring in part and dissenting in part). ¶22 The juvenile court correctly analyzed and applied the remaining Michael J. factors.

2020Id. at 252, ¶ 29 . ¶9 Here, the superior court made specific findings regarding each of the Michael J. factors including that Father has been in custody for most of Son’s life and will not be released until at least 2021.

2026Sec., 214 Ariz. 445, 450, ¶ 15 (App. 2007). ¶14 The superior court assessed each of the Michael J. factors and its findings were supported by reasonable evidence. ¶15 Pre-incarceration relationship.

2024Thus, depending on the circumstances, “[a] lack of evidence on one or several of the Michael J. factors may or may not require reversal or remand on a severance order.” Id.

2020The "normal home" to which the statute refers is "a home in which the respondent natural father has a presence, and it does not refer to a 'normal home' environment created by [others]." Jeffrey P. v. Dep't of Child Safety, 239 Ariz. 212, 215, ¶ 14 (App. 2016) (quoting Maricopa Cty.

2016See Jeffrey P., 239 Ariz. at 214, ¶ 10 (noting that when a court addresses the incarceration ground for termination of parental rights, the court is not required to presume an early release). ¶17 After considering the evidence presented to the juvenile court in light of the Michael J. factors, we conclude that reasonable evidence supports the juvenile court’s finding that DCS met its burden of showing the length Father’s sentence has deprived A.S. of a normal home for a period of years pursuant to A.R.S. § 8-533(B)(4).

2009See Jesus M., 203 Ariz. 278, ¶ 12 , 53 P.3d at 207 (appellate court will not disturb order terminating parental rights absent clear abuse of discretion). ¶ 6 Additionally, to the extent Antonio is suggesting the juvenile court’s order was nevertheless deficient because the court should have more specifically set forth each of the Michael J. factors it had considered, he did not make that objection below.' “[W]hen a party fails to object below to ‘the alleged lack of detail in the juvenile court’s findings,’ the issue is deemed waived when raised for the first time on appeal____” Marco C. v. Se

2009See Jesus M., 203 Ariz. 278, ¶ 12 , 53 P.3d at 207 (appellate court will not disturb order terminating parental rights absent clear abuse of discretion). ¶ 6 Additionally, to the extent Antonio is suggesting the juvenile court’s order was nevertheless deficient because the court should have more specifically set forth each of the Michael J. factors it had considered, he did not make that objection below.' “[W]hen a party fails to object below to ‘the alleged lack of detail in the juvenile court’s findings,’ the issue is deemed waived when raised for the first time on appeal____” Marco C. v. Se

2009See Jesus M., 203 Ariz. 278, ¶ 12 , 53 P.3d at 207 (appellate court will not disturb order terminating parental rights absent clear abuse of discretion). ¶ 6 Additionally, to the extent Antonio is suggesting the juvenile court’s order was nevertheless deficient because the court should have more specifically set forth each of the Michael J. factors it had considered, he did not make that objection below.' “[W]hen a party fails to object below to ‘the alleged lack of detail in the juvenile court’s findings,’ the issue is deemed waived when raised for the first time on appeal____” Marco C. v. Se

2009See Jesus M., 203 Ariz. 278, ¶ 12 , 53 P.3d at 207 (appellate court will not disturb order terminating parental rights absent clear abuse of discretion). ¶ 6 Additionally, to the extent Antonio is suggesting the juvenile court’s order was nevertheless deficient because the court should have more specifically set forth each of the Michael J. factors it had considered, he did not make that objection below.' “[W]hen a party fails to object below to ‘the alleged lack of detail in the juvenile court’s findings,’ the issue is deemed waived when raised for the first time on appeal____” Marco C. v. Se

2020Mary Lou C., 207 Ariz. at 47, ¶ 8 .

2016Sec. v. Rocky J., 234 Ariz. 437, 441, ¶ 14 (App. 2014) (citation and quotations omitted). ¶11 Here, the juvenile court made express and substantial findings regarding the relevant Michael J. factors.