In re Aubrey R., 157 A.3d 212

Petition to terminate parental rights of the mother and father under 22 M.R.S. § 4055(l)(A)(1)(a) and (B)(2) (2016).
Trial court found the mother unable to protect Aubrey from jeopardy and unable to take responsibility within a reasonable time.
Mother continued to associate with unsafe individuals, including the father, in violation of a jeopardy order and reunification plan.
Evidence showed the threat of serious harm to the child due to the mother's failure to protect and ongoing exposure to domestic violence and drug abuse.
The court also found the termination to be in the child’s best interests; the father’s arguments were not persuasive on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the findings of parental unfitness were sufficient for appellate review	Mother argues findings are insufficient to inform basis for termination	Court maintained sufficient, explicit findings to enable review	Yes; findings inform basis for unfitness
Whether the evidence supports the mother’s inability to protect from jeopardy in a reasonable time	Department contends evidence shows risk due to mother’s ongoing contact with father	Mother asserts insufficient proof of threat of serious harm	Yes; clear and convincing evidence supports inability to protect from jeopardy
Whether termination was in Aubrey’s best interests	Department argues best interests support termination given risk factors	Mother contends best interests may not justify termination given other factors	Yes; court did not err in best interests finding

In re Amber B., 597 A.2d 937 (Me. 1991) (foundations requiring explicit factual findings for termination to allow meaningful review)
In re David G., 659 A.2d 859 (Me. 1995) (findings sufficient to inform basis for termination even if not perfect)
In re Dylan B., 2001 ME 31 (Me. 2001) (lack of findings or mere summary can be insufficient for review)
In re K.M., 2015 ME 79 (Me. 2015) (affirmation based on any single supported basis among multiple)
In re Jazmine L., 2004 ME 125 (Me. 2004) (emotional harm standard requires sufficient severity)
In re Cameron Z., 2016 ME 162 (Me. 2016) (unfitness supported by mother's unwillingness to end risky relationship)