In re Adden B., 144 A.3d 1158

Adden B. entered foster care one day after birth (Sept. 2014) after reports of parental mental-health issues, domestic violence, and the mother’s stated unwillingness to care for the child. The Department obtained a preliminary protection order.
January 2015: the court found the father (Gary B.) in jeopardy due to domestic violence, unmanaged mental-health/anger problems, and an untreated 2005 sexual-offender conviction; the court ordered multiple rehabilitative services including sexual-offender treatment and a batterers’ program.
April 2015: the Department petitioned to terminate the father’s parental rights, alleging he refused ordered treatments and took no steps toward reunification.
Termination hearing held Sept. 30, 2015: the father left the courthouse mid-hearing, claiming acute illness, but promised to provide a doctor’s note by the following Monday to obtain a de novo hearing; he did not submit any medical documentation and did not return.
The father’s attorney remained, cross-examined Department witnesses, and did not present defense witnesses. The court terminated the father’s parental rights (Oct. 23, 2015), finding unresolved jeopardy, refusal to engage in services, lack of contact with the child, and that permanency would be impeded by placement with the father. The father appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conducting the termination hearing in father’s absence violated due process	Father: his departure was involuntary due to acute illness; proceeding violated his right to be heard	State/Dept: father voluntarily left despite being offered options (stay or submit medical note for de novo hearing); counsel participated	Court affirmed: no due-process violation — father had notice, opportunity to be heard via counsel or by rescheduling if he provided medical proof; his absence was voluntary

State v. Jones, 55 A.3d 432 (Maine 2012) (standard of de novo review for procedural due-process questions)
In re Robert S., 966 A.2d 894 (Maine 2009) (due-process review framework cited)
In re M.P., 126 A.3d 718 (Maine 2015) (due-process requirement: meaningful opportunity to be heard)
In re A.M., 55 A.3d 463 (Maine 2012) (due process in termination hearings requires notice, opportunity to be heard, present evidence, confront witnesses, and impartial factfinder)