In re Kaylianna C., 166 A.3d 976

Father (Massachusetts resident) had limited contact with daughter; paternity established after child-protection case began. Father had not meaningfully engaged in reunification or complied with visitation; ICPC study did not recommend placement with him.
Jeopardy order was entered in April 2016 based on father’s failure to protect the child. Father was served with termination petition and notified of a three-day termination hearing.
Father did not appear when the termination hearing began December 2, 2016; his attorney attended and did not ask for a continuance. The Department presented the caseworker’s testimony and prior records; father presented no evidence.
The court orally announced termination of father’s parental rights, finding four statutory grounds of parental unfitness and that termination was in the child’s best interest; written judgment followed.
Six days after the hearing, the father filed a Rule 59 motion claiming he missed the hearing because his car was stolen the night before; he did not explain why he didn’t notify counsel or the court that day, provide proof of the theft, or offer an offer of proof of the testimony he would have given.
The court summarily denied the Rule 59 motion; father appealed only on due-process grounds (absence at hearing and denial of new trial/alternative opportunity to be heard).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination violated due process because father was absent from hearing	Father: absence was involuntary (vehicle stolen) and he was deprived of an opportunity to be heard	State: father’s absence was voluntarily created or unexplained; he failed to offer proof of what his testimony would have shown	Court: No due-process violation; father didn’t explain how presence would have changed outcome or make an offer of proof
Whether summary denial of Rule 59 motion was an abuse of discretion	Father: court should have given more explanation or granted new trial/alternative hearing	State: court made required findings in its oral/written decision; Rule 59 did not require additional findings absent a showing	Court: Denial not an abuse of discretion; Rule 52(a) requirements satisfied and father offered no timely, specific offer of proof

In re Tacoma M., 160 A.3d 537 (Me. 2017) (statutory standard for parental unfitness and termination)
In re Kayleigh P., 165 A.3d 340 (Me. 2017) (standard for sufficiency of findings supporting termination)
Arundel Valley, LLC v. Branch River Plastics, Inc., 151 A.3d 938 (Me. 2016) (review of denial of new trial for abuse of discretion)
In re Mark M., 581 A.2d 807 (Me. 1990) (procedural review principles in termination contexts)
In re A.M., 55 A.3d 463 (Me. 2012) (due-process requirements in termination proceedings; offer-of-proof principle)
In re Adden B., 144 A.3d 1158 (Me. 2016) (parental absence and voluntariness analysis)
In re Randy Scott B., 511 A.2d 450 (Me. 1986) (rejecting due-process challenge where absent parent showed no prejudice)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (framework for assessing procedural due process)