In re Children of Danielle M., 222 A.3d 608

December 2017: DHHS removed three children (ages 8, 4, 2) after incidents alleging mother's alcohol/drug use and multiple violent altercations in the children's presence; father's conduct included a crowbar altercation and a separate domestic violence incident.
Court placed children in DHHS custody, entered a jeopardy order (March 2018) with a reunification plan requiring mental-health and substance-abuse evaluations, treatment, random drug testing, and supervised visitation.
Mother attended supervised visits but failed to engage consistently in mental-health counseling or sustained substance-abuse treatment, produced only three drug screens (all positive), and displayed ongoing alcohol use and housing instability.
Father obtained only a limited psychosocial screening, expressed no personal interest in reunification, and was arrested in October 2018 on serious criminal charges and remained incarcerated pending trial.
Children had stable, well-adjusted foster placements and were participating in counseling; DHHS found to have made reasonable reunification efforts.
May 2019: District Court terminated mother’s parental rights to all three children and father’s rights to the youngest child; parents appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to terminate mother’s parental rights	Mother: evidence insufficient to show unfitness or that termination served children’s best interests	State: mother failed to complete reunification tasks, continued substance use, unstable housing, no meaningful progress in 17 months	Court: competent evidence supported clear-and-convincing findings of unfitness and best-interest termination; judgment affirmed
Sufficiency of evidence to terminate father’s parental rights	Father: insufficient evidence of unfitness and of best-interest justification	State: father disavowed reunification, failed to complete required evaluations, was incarcerated and posed delay to reunification	Court: evidence supported findings of unfitness and best-interest termination; judgment affirmed
Adequacy of DHHS reunification services (father’s claim)	Father: DHHS failed to provide appropriate/necessary reunification services	State: DHHS developed and offered a plan; father was not cooperative or interested in reunification	Court: DHHS’s efforts were sufficient; any shortcomings do not preclude findings of parental unfitness; claim rejected

In re Daniel H., 160 A.3d 1182 (Me. 2017) (standard of review and parental-unfitness framework)
In re Gabriel W., 166 A.3d 982 (Me. 2017) (deference to trial court’s factfinding and best-interest analysis)
In re Thomas D., 854 A.2d 195 (Me. 2004) (context on reunification services and Department obligations)