In re Cameron Z., 150 A.3d 805

DHHS filed child protection petitions in Feb 2014 after a newborn (Lawrence) was born drug-affected and a six-year-old (D.G.) presented with inflicted bruises; the newborn was placed in DHHS custody and the older children were later placed under a safety plan.
The court entered jeopardy orders in May 2014 as to both parents, finding the father failed to protect children from domestic violence and abandonment and the mother had substance-abuse and supervision deficiencies; the mother’s custody was conditioned on no contact between the father and the children without DHHS approval.
The father repeatedly failed to appear for hearings, did not participate in services, missed supervised visits, maintained a clandestine relationship with the mother, and was found to have abandoned the children.
The mother has a long history of substance abuse, engaged inconsistently with offered services, and refused or failed to separate reliably from the father, undermining reunification prospects.
The children were exposed to domestic violence and had behavioral and adjustment issues; three of the children (Cameron, Cole, Lawrence) were doing well in their placements and one (Calvin) was struggling but needed permanence.
After multi-day termination hearings, the District Court terminated both parents’ rights to all four children; mother consented to termination of Lawrence but did not challenge that part of the judgment on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to find parental unfitness and that termination is in children’s best interest	DHHS: Clear and convincing evidence showed parents were unwilling/unable to protect children, unlikely to change, father abandoned children; termination served children’s need for permanency	Parents: Evidence insufficient to show unfitness or that termination was in best interest	Court: Affirmed — findings supported by record; termination proper under 22 M.R.S. § 4055(1)(B)
Admissibility of hearsay statements by one child (father’s claim)	DHHS: Trial evidence properly admitted; statements were reliable and did not prejudice father	Father: Court erred in admitting hearsay statements	Court: No reversible error; claim did not warrant relief
Judicial recusal motion by father	DHHS: Judge acted appropriately; no disqualifying bias	Father: Trial judge should have recused	Court: No error in denying recusal; appeal on this point fails

In re K.M., 118 A.3d 812 (2015) (standard for reviewing factual findings and sufficiency in parental-termination appeals)
In re R.M., 114 A.3d 212 (2015) (clear-and-convincing-evidence standard and appellate review framework)
State v. Lowden, 106 A.3d 1134 (2014) (appellate review of trial-court factual findings)
In re Thomas H., 889 A.2d 297 (2005) (centrality of permanency in child-protective proceedings)