IN RE TY'VONNA LEA HARRIS MINOR
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STATE OF MICHIGAN
COURT OF APPEALS
__________________________________________
In the Matter of TY’VONNA LEA HARRIS, Minor.
FAMILY INDEPENDENCE AGENCY,
UNPUBLISHED
February 16, 1999
Petitioner-Appellee,
v
No. 211389
Ingham Circuit Court
Family Division
LC No. 004059
DIANNIA HARRIS,
Respondent-Appellant.
Before: Murphy, P.J., and MacKenzie and Talbot, JJ.
MEMORANDUM.
Respondent appeals as of right from the juvenile court order terminating her parental rights to
the minor child under MCL 712A.19b(3)(c)(i), (g), (i), and (j); MSA 27.3178(598.19b)(3)(c)(i), (g),
(i), and (j). We affirm. This case is being decided without oral argument pursuant to MCR 7.214(E).
Relying on the waiver of counsel requirements for criminal proceedings set forth in People v
Anderson, 398 Mich 361; 247 NW2d 857 (1976), respondent contends that reversal is required
because the juvenile court did not substantially comply with the requirements for obtaining a valid waiver
set forth in Anderson. We disagree. In view of the differences in the applicable court rules for securing
a waiver of counsel in criminal and child protective proceedings, compare MCR 6.005 and MCR
5.915(B)(1)(c) respectively, we are not convinced that the same standards that govern a waiver of
counsel in criminal proceedings apply to child protective proceedings. Moreover, any error in failing to
sufficiently advise respondent about the dangers of self-representation was harmless. See People v
Geoghegan, 456 Mich 945; 576 NW2d 168 (1998).
Next, respondent challenges the termination of her parental rights under § 19b(3)(g) only.
Because only one statutory ground is necessary to terminate parental rights and because respondent
does not challenge the termination of her parental rights under §§ 19b(3)(c)(i), (i) and (j), she is not
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entitled to appellate relief. Roberts & Son Contracting, Inc v North Oakland Development Corp,
163 Mich App 109, 113; 413 NW2d 744 (1987).
Affirmed.
/s/ William B. Murphy
/s/ Barbara B. MacKenzie
/s/ Michael J. Talbot
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