In re Christopher S., 203 A.3d 808

DHHS filed child protection petition Dec 2017 after repeated reports (2009–2016) alleging the father’s physical/emotional abuse and failure to meet children’s medical/educational/mental‑health needs; children were placed with the mother under a preliminary protection order.
An agreed jeopardy order (Jan 2018) found the father’s unmanaged mental health and domestic violence posed serious risk; he was ordered to undergo diagnostic evaluation, DBT, and medication management.
The father largely refused or failed to engage in services; a counselor left citing safety concerns after the father made threatening remarks; he intermittently posted threatening comments on social media.
DHHS petitioned to terminate the father's parental rights; at the August 2018 hearing the father did not testify; court found him unwilling/unable to protect the children, unlikely to change within a timeframe meeting the children’s needs, and that he failed to make good‑faith rehabilitative efforts.
Psychological evaluation diagnosed antisocial personality disorder and polysubstance use disorder, concluding the father was unlikely to provide a safe, stable environment and had a poor prognosis for treatment compliance.
The court terminated the father’s parental rights while leaving custody with the mother; father appealed only the best‑interest/permanency conclusion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination of father's parental rights provides the children with "permanency" and is in their best interests	Father argued the court erred; termination is not required to achieve permanency or serve children’s best interests	DHHS and mother argued record showed ongoing, escalating risk from father, his refusal to engage in services, and children's need for safety, stability, and permanence	Court affirmed: clear‑and‑convincing findings supported that termination was in the children’s best interests and would provide permanency
Whether a parental rights and responsibilities order (preserving father’s rights) would suffice instead of termination	Father argued children could remain with mother without terminating his rights and that a PR&R order should have been entered	DHHS argued father’s continued presence and refusal to engage posed a constant, extreme threat and termination was warranted despite children remaining with mother	Court affirmed termination was proper under facts; terminating one parent’s rights while preserving the other’s was justified here

In re Children of Corey W., 199 A.3d 683 (Me. 2019) (standards for reviewing factual findings)
In re Child of Jonathan D., 200 A.3d 799 (Me. 2019) (termination of one parent’s rights while preserving the other’s)
In re Children of Nicole M., 187 A.3d 1 (Me. 2018) (standard of review for best‑interest findings)
In re Child of Mercedes D., 196 A.3d 888 (Me. 2018) (statutory factors for best‑interest determination)
Adoption of Isabelle T., 175 A.3d 639 (Me. 2017) (consideration of harm if parental rights not terminated and need for permanence)
In re Ashley A., 679 A.2d 86 (Me. 1996) (relation of parental unfitness findings to best‑interest analysis)
In re Child of Emily K., 187 A.3d 595 (Me. 2018) (affirming termination of one parent’s rights while preserving the other’s)
In re Child of Domenick B., 197 A.3d 1076 (Me. 2018) (unfit parent and best‑interest inquiry)
In re Thomas H., 889 A.2d 297 (Me. 2005) (standards for termination best‑interest determination)