In re Keegan M., 171 A.3d 586

Keegan M., removed from parents in Feb 2015 after a jeopardy finding for unsanitary, unsafe, unstable conditions and lack of supervision; placed with maternal aunt and has since shown substantial improvement.
Reunification plan required parents to obtain psychological evaluations, counseling, medication management, case management, and safe stable housing.
Mother did not engage in counseling, case management, or consistent medication management until late 2016; she blamed the Department, a claim the court found not credible.
Father did not participate in case management, medication management, or counseling and testified he could not provide shelter for Keegan.
Both parents have untreated serious mental-health conditions that the court found impair their parenting and ability to protect Keegan within a time reasonably calculated to meet his needs.
Trial court found by clear and convincing evidence that parents were unwilling or unable to protect Keegan and that termination of parental rights with a permanency plan of adoption was in Keegan’s best interests; appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory grounds for termination were proven	Parents (father generally; mother argued Dept failed to provide services) challenged factual findings	Parents contended insufficient proof and lack of services (mother)	Court found clear and convincing evidence parents were unwilling/unable to protect Keegan and met statutory grounds; affirmed
Whether Department failed to provide necessary services (mother's claim)	Mother: Department’s failures explain her delayed participation	Department: provided services and repeatedly requested participation; mother’s excuse not credible	Court credited Department; rejected mother’s claim of inadequate services
Credibility and weight of evidence	Father challenged factual findings broadly	Department relied on evaluations, history, and caretakers’ reports	Appellate court deferred to trial court’s credibility findings and did not disturb them
Best interest / permanency plan	Parents argued termination not in child’s best interest	Department: Keegan’s progress with aunt and need for predictability supports adoption	Court found termination and adoption plan serve Keegan’s best interests and affirmed

In re Caleb M., 159 A.3d 345 (Me. 2017) (standard for termination and best-interest review)
In re Cameron B., 154 A.3d 1199 (Me. 2017) (deference to trial court credibility determinations)
In re I.S., 121 A.3d 105 (Me. 2015) (requirement that at least one ground for parental unfitness be established)
In re Jazmine L., 861 A.2d 1277 (Me. 2004) (linking parents’ deficits to child’s individual needs)
In re Thomas H., 889 A.2d 297 (Me. 2005) (discretion in determining termination and permanency planning)
In re M.C., 104 A.3d 139 (Me. 2014) (counsel’s obligation when appeal lacks merit)