In re Child Daniel Q., 182 A.3d 735

Father (Daniel Q.) appealed a District Court judgment terminating his parental rights under 22 M.R.S. § 4055; mother consented to termination and did not appeal.
Child had lived his entire life in nonparental care; termination was sought based on parental unfitness for inability/unwillingness to protect and failure to rehabilitate/reunify.
Court found father had made little progress in parenting skills, lacked insight into his relationship problems, and blamed women for his difficulties.
Father had criminal history including convictions for domestic violence and violating a protective order, and multiple protective orders had been filed against him.
Father lacked stable housing and financial ability to support the child and had not made sustained efforts to reunify despite Department services.
Court concluded the child (about 18 months old) could not wait for the father to rehabilitate and that termination was in the child’s best interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court erred in finding parental unfitness under §4055(1)(B)(2)(b)(i),(iv)	Department: clear and convincing evidence father unwilling/unable to protect child and failed to make good‑faith rehabilitative efforts	Father: appealed judgment (argued errors in court’s unfitness finding)	Affirmed — competent evidence supports unfitness finding
Whether father’s criminal history and protective orders justify termination	Department: criminal history and protective orders show inability to provide safe environment	Father: contended court erred in weighing evidence (implicit)	Affirmed — those facts supported conclusion father could not protect child
Whether lack of stable housing/support precludes reunification within child’s needed timeframe	Department: father’s housing/financial instability unlikely to change in time for child’s developmental needs	Father: argued insufficient grounds to terminate based on these conditions (implicit)	Affirmed — child’s age and need made waiting unreasonable
Whether termination is in child’s best interest	Department: termination serves child’s developmental and safety needs; father hasn’t reciprocated services	Father: did not challenge best‑interest finding on appeal	Affirmed — record supports best‑interest determination

In re Zarianna C., 177 A.3d 1270 (Me. 2018) (standard of review for factual findings supporting unfitness)
In re Zianna G., 174 A.3d 889 (Me. 2017) (review limited to competent evidence and credibility determinations)
In re Anastasia M., 172 A.3d 922 (Me. 2017) (best‑interest finding review in parental termination context)