In re Domenick B., 197 A.3d 1076

Child born Dec. 2013; maternal grandparents brought child to Maine; father and later mother returned to Maine after mother's incarceration.
Father arrested for assaulting the mother with the child present; DHHS filed child protection petition alleging substance abuse, anger, and domestic violence; child placed with maternal grandparents under a jeopardy order.
Jeopardy order required father to complete substance-abuse evaluation, individual therapy for childhood trauma and anger, random drug screens, and avoid nonprescribed mood-altering substances.
DHHS petitioned to terminate the father's parental rights in Nov. 2017; two-day hearing held May–June 2018; mother consented to termination.
Court found father failed to complete required mental-health treatment (sporadic attendance then stopped Oct. 2017), continued alcohol use despite warnings, and made insufficient progress toward alleviating jeopardy after nearly two years of reunification efforts.
Child had been in grandparents' custody since Aug. 25, 2016; court emphasized child's need for permanency and noted strained relationship between father and grandparents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was clear and convincing evidence the father was unfit / unable to protect child or take responsibility within a reasonable time	DHHS: Father’s inconsistent therapy, ongoing alcohol use, and failure to alleviate jeopardy support finding of parental unfitness	Father: Evidence insufficient to show parental unfitness by clear and convincing standard	Court: Affirmed — competent evidence supports finding of unfitness (failed treatment, continued alcohol use, insufficient progress)
Whether termination (versus a permanency guardianship) was in child’s best interest	DHHS/guardian ad litem: Termination provides permanency given father's lack of progress and strained relations with caregivers	Father: If unfit, court should impose a permanency guardianship to preserve legal relationship and contact	Court: Affirmed termination — court considered guardianship but denied it due to relationship strain and child’s need for stable, permanent home

In re Children of Nicole M., 187 A.3d 1 (Me. 2018) (standard for drawing facts from judgment and record)
In re Thomas D., 854 A.2d 195 (Me. 2004) (definition and proof of parental unfitness; timing for reunification efforts)
In re A.M., 55 A.3d 463 (Me. 2012) (review of evidentiary support for termination findings)
In re Haylie W., 167 A.3d 576 (Me. 2017) (abuse-of-discretion review for permanency decisions)
In re Cameron B., 154 A.3d 1199 (Me. 2017) (purpose and function of permanency guardianship)
In re Michaela C., 809 A.2d 1245 (Me. 2002) (courts’ deference in best-interest determinations)
In re Scott S., 775 A.2d 1144 (Me. 2001) (requirement to determine best interest after finding parental unfitness)
In re Thomas H., 889 A.2d 297 (Me. 2005) (affirming termination where reunification efforts insufficient)