In Re Dakota K., 133 A.3d 257

Parents (mother of Aiden and Benjamin; father of Carl, Daryl, and Benjamin) appealed termination of parental rights after a three-day District Court trial under 22 M.R.S. § 4055(1)(A)(1)(a) and (B)(2).
Court found both parents unwilling or unable to protect the children and meet their needs within a reasonable time; also found termination in children’s best interests. The father was additionally found to have failed to make a good-faith effort to rehabilitate and reunify.
DHHS provided a preliminary rehabilitation and reunification plan to the father identifying safety concerns (home conditions, unsafe relative access), required assessments, and treatment referrals; father refused to sign and was often uncooperative or unreachable.
Father failed to attend a psychological assessment, refused counseling and drug screenings, and did not secure new housing while an identified unsafe relative lived next door.
Mother had documented mental-health diagnoses and inconsistent medication/ treatment management; she was required to engage in counseling and medication management but the court found her mental-health issues impeded safe parenting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was improper because DHHS failed to complete a formal rehabilitation/reunification plan	Father: DHHS did not meet statutory reunification duties; no formal plan agreed upon	DHHS: father was the cause of failure to complete plan; plan requirements were communicated	Court: Father’s noncooperation caused failure; DHHS met duties and findings of unfitness stand
Whether father was unfit for failing to rehabilitate/reunify	Father: error to find unfit absent DHHS compliance	Father: argued lack of agreed plan; also claimed DHHS fault	Court: Held father failed to make good-faith efforts; unfitness established
Whether mother’s mental health supported finding of unfitness	Mother: Court lacked expert testimony proving diagnoses impaired parenting; court misweighed evidence	DHHS: mother’s inconsistent treatment and medication management created jeopardy; reunification plan required mental-health compliance	Court: Evidence (including mother’s testimony and history) supported inference that mental-health issues prevented safe care
Whether termination is in children’s best interests	Parents: argued court erred in weighing favorable evidence	DHHS: best-interest evidence supports termination	Court: Ample record evidence supports best-interest finding; termination affirmed

In re Thomas D., 854 A.2d 195 (Me. 2004) (failure to complete reunification plan is an important factor at termination)
In re Doris G., 912 A.2d 572 (Me. 2006) (focus is whether reunification obligations were communicated to parent)
State v. Woodard, 68 A.3d 1250 (Me. 2013) (trial court may draw reasonable inferences from the evidence)
In re Marpheen C., 812 A.2d 972 (Me. 2002) (appellate review of trial court’s weighing of evidence in child protection cases)
In re Jazmine L., 861 A.2d 1277 (Me. 2004) (court may rely on inferences supporting ultimate findings)
In re I.S., 121 A.3d 105 (Me. 2015) (standards for proving parental unfitness)
In re C.P., 67 A.3d 558 (Me. 2013) (best-interest analysis in termination decisions)

Judgment affirmed.