In re Children of Christine A., 207 A.3d 186

DHHS initiated child protection proceedings in Feb 2016 alleging mother's substance abuse and mental health issues; children placed in Department custody and a jeopardy order was entered.
Mother diagnosed with PTSD and unspecified psychotic disorder; prescribed medications and engaged intermittently in psychiatric and substance-abuse treatment, with multiple relapses and missed sessions.
Mother had periods of progress (residential and outpatient programs, visits), but relapsed (including an incident in Jan 2017 when she appeared unstable while holding the younger child), failed drug tests, and was discharged from some treatment programs.
Department petitioned to terminate parental rights on May 15, 2017; bench hearing occurred July 9–10, 2018; mother sought to exclude two school counselors’ testimony at start of trial as untimely—motion denied as untimely.
Trial court found by clear and convincing evidence that mother was unfit under 22 M.R.S. § 4055(1)(B)(2)(b)(i) and (ii) (unable/unwilling to protect or take responsibility within a time meeting the children’s needs) and that termination was in the children’s best interests; judgment terminating parental rights was entered July 26, 2018.
Mother appealed challenging unfitness findings, best-interest determination, and denial of the limine motion; appellate court affirmed and declined to find abuse of discretion or clear error; separate Rule 60(b)(6) relief and IAC claims were denied below and not pursued on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for parental unfitness	Mother: successes in rehabilitation show she can protect children and take responsibility	State: record of relapses, missed treatment, instability shows continued jeopardy and inability to remediate within a reasonable time	Affirmed — court’s findings supported by clear and convincing evidence; not clearly erroneous
Best-interest determination	Mother: additional counseling could allow reunification; conflicting evidence of progress	State: children have been in care >3 years and are thriving; need permanency and stability	Affirmed — no abuse of discretion; termination serves children’s best interests
Denial of last-minute motion in limine to exclude two school counselors	Mother: counsel testimony and records not produced in discovery	State: counselors were listed on witness list months earlier; motion was filed at trial start and untimely	Affirmed — denial not an abuse of discretion; motion untimely and mother failed to subpoena or seek earlier discovery
Denial of post-judgment relief for ineffective assistance of counsel (related proceedings)	Mother: trial counsel ineffective including handling of motion in limine	State: District Court considered and denied Rule 60(b)(6) motion on merits; mother did not pursue this denial on appeal	Not challenged on appeal; appellate court did not review that denial here

In re Child of James R., 182 A.3d 1252 (Me. 2018) (standards for parental unfitness and best-interest review)
In re Keegan M., 171 A.3d 586 (Me. 2017) (trial court’s credibility and weight determinations govern in termination cases)
In re Alexandria C., 152 A.3d 617 (Me. 2016) (standards for Rule 60(b)(6) relief in child-termination context)
Halliday v. Henry, 116 A.3d 1270 (Me. 2015) (procedural waiver when issues not briefed on appeal)
In re Kayla S., 772 A.2d 858 (Me. 2001) (review standard for trial court evidentiary rulings)