In re Amber L., 188 A.3d 876

Child was removed and custody granted to DHHS on October 21, 2016; mother retained supervised visitation and has a bond with the child.
Two-day termination hearing held in Feb. 2018; court found mother unwilling/unable to protect child and take responsibility and unlikely to improve within a time meeting child’s needs under 22 M.R.S. § 4055(1)(B)(2).
Mother has long-standing cannabis use disorder, personality disorder, and complex PTSD; she self-medicates with marijuana and has inconsistent mental-health treatment attendance.
Mother attended methadone clinic and supervised visits, but therapy participation (DBT groups and individual therapy) was sporadic and insufficient for recommended long-term treatment.
Mother demonstrated repeated involvement with unsafe relationships and police contacts; child has special needs requiring high-level, stable care and prompt permanency.
District Court terminated mother’s parental rights as in child’s best interest; father’s rights were also terminated after he failed to appear (father not party to this appeal).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports parental unfitness	Mother: her progress (clinic attendance, supervised visits) shows circumstances likely to change in reasonable time	State/DHHS: mental-health and substance-use disorders are longstanding and unlikely to resolve without intensive, long-term treatment; evidence shows continued jeopardy	Affirmed: competent evidence (mental-health testimony, treatment history, instability) supports finding of parental unfitness
Whether termination was in the child’s best interest given kinship placement could provide stability	Mother: statute favors family rehabilitation/reunification; additional time should be granted since kinship placement is stable	State: statutory mandate balances reunification with preventing needless delay; child needs permanency given special needs and mother’s instability	Affirmed: court reasonably found further delay contrary to child’s best interest and terminated rights

In re Child of Kelcie L., 184 A.3d 387 (Me. 2018) (standard for review and relevance of permanency vs. rehabilitation)
In re Cameron B., 154 A.3d 1199 (Me. 2017) (standards for parental unfitness findings and best-interest discretion)
In re Mathew H., 167 A.3d 561 (Me. 2017) (treatment needs and prognosis inform unfitness findings)
In re Marcus S., 916 A.2d 225 (Me. 2007) (instability undermines permanence)
In re Dakota K., 133 A.3d 257 (Me. 2016) (courts may deny delay when further postponement harms child's need for permanency)