In re James C., 177 A.3d 1279

Father appealed termination of his parental rights under 22 M.R.S. § 4055, arguing the court erred finding him unfit and that termination was not in the child's best interest.
Court findings: father has extensive mental-health, impulse-control, anger-management, and domestic-violence issues; he blames others and minimizes his conduct, showing little insight or acceptance of responsibility.
Father has difficulty managing finances (representative payee), missed evaluation sessions, and showed only limited progress in supervised visits; CODE evaluator concluded he lacked necessary intellectual, emotional, and maturational parenting skills.
Child was born prematurely with complex medical and therapeutic needs (nephrology, special diet, OT, speech) requiring careful, skilled caregiving; child is in therapeutic foster care and needs permanency and likely adoption.
Child had been in foster care over a year; statutory framework favors timely move to permanency and mandates filing termination petitions in specified prolonged foster-care circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether father is unfit under §4055(B)(2)(b)(i),(ii),(iv)	Father contends love and bond with child and needs more time for reunification	Record shows clear and convincing evidence of unfitness: mental-health, domestic violence, lack of insight, inability to meet child’s needs	Court found father unfit on three independent statutory grounds; affirmed
Whether father was given adequate time/opportunity to rehabilitate	Father argued he needed more than ~1 year to engage services and reunify	Statute and record show he had reasonable time and failed to engage meaningfully; Legislature favors timely permanency	Court held time was adequate and statute supports moving toward permanency
Whether child’s bond with father precludes termination	Father argued bond favors keeping parental rights to allow reunification	Court: bond is one factor but does not override unfitness and the child’s specialized needs	Court held bond insufficient to overcome unfitness and best-interest concerns
Whether termination is in the child’s best interest	Father argued continued efforts/reunification would serve child’s interest	Child’s complex medical needs require stable, skilled caregivers; father unable to manage his own needs let alone child’s	Court exercised discretion to terminate to allow adoption and permanency; affirmed

In re K.M., 118 A.3d 812 (Me. 2015) (standards for proving parental unfitness)
In re Michaela C., 809 A.2d 1245 (Me. 2002) (parent-child bond is only one factor in best-interest analysis)
In re Alana S., 802 A.2d 976 (Me. 2002) (statutory purpose favors prompt permanency)
In re Joseph V., 169 A.3d 389 (Me. 2017) (court discretion to terminate when adoption serves child’s needs)
In re Jeffrey E., 557 A.2d 954 (Me. 1989) (best-interest framework supports termination in appropriate cases)
In re David G., 659 A.2d 859 (Me. 1995) (bond with parent does not automatically prevent termination)

Judgment affirmed.