In re Children of Amber L., 184 A.3d 19

Two children were removed from parental custody in 2008, remained in foster care until 2012, then shuttled between parents’ homes; formal Department involvement began in summer 2015.
Over a 20-month period the Department implemented reunification plans; parents had services and transportation assistance but failed to remedy jeopardy to the children.
Mother: minimal visitation (three visits), refused counseling and parenting sessions, denied relevance of past substance abuse/domestic violence/mental health issues, and made comments undermining attachment to foster parents.
Father: engaged in some services but lacked stable housing, continued to live with persons he agreed should not be around the children, showed limited insight into his substance abuse impact, and blamed the children for behavior problems.
Both children have significant trauma-related and behavioral needs; each placed in separate therapeutic foster homes with stable long-term caregivers who are not committed pre-adoptively. Therapists testified permanency is urgent for effective treatment; family therapy could help only if parents acknowledge past abuse/neglect.
District Court terminated both parents’ rights under 22 M.R.S. § 4055(1)(A)(1)(a) and (B)(2)(a),(b)(i)-(ii) (and additional §4055 grounds as to the mother); parents appealed. Judgment affirmed.

Issue	Father’s Argument	Mother’s Argument	Held
Whether evidence supports finding parents unwilling/unable to protect children from jeopardy and unlikely to change within a time meeting children’s needs	Insufficient evidence of unfitness and best-interest justification; court failed to weigh negative consequences of termination	(mother did not file an appellate brief asserting arguable issues)	Court: Findings supported—both parents unwilling/unable to protect or take responsibility; termination statutory grounds met
Whether mother made good-faith efforts to rehabilitate and reunify	N/A on appeal (mother conceded no meritorious issues)	Mother argued past issues are over and services were unnecessary	Court: Mother failed to make good-faith efforts (refused counseling, minimal visitation)
Whether termination is in children’s best interests given foster families are not immediately adoptive	Termination is premature and does not ensure permanency if foster families won’t adopt	N/A on appeal	Court: Termination appropriate—permanency is dynamic; parents failed to alleviate jeopardy over 20 months despite support
Whether trial court erred by adopting Department proposed findings (failure to exercise independent judgment)	Father argues adoption showed lack of independent judgment	N/A	Court: Argument not entertained because father failed to seek further findings under M.R. Civ. P. 52(b)

In re Meena H., 177 A.3d 1276 (2018) (statutory standards for termination under §4055)
In re Marcus S., 916 A.2d 225 (2007) (permanency is a dynamic, case-specific concept)
In re Kenneth S., 157 A.3d 244 (2017) (distinguishing best-interest/permanency from adoptive suitability)
In re M.C., 104 A.3d 139 (2014) (procedure for appellate counsel to report no-merit issues)
In re Caleb M., 159 A.3d 345 (2017) (requirement to move for further findings under M.R. Civ. P. 52(b) before challenging court’s independent judgment)