In re L.T., 120 A.3d 650

Child born 2008 to unmarried parents; parents separated soon after birth; protection-from-abuse orders limited father's contact.
DHHS became involved in 2012 after domestic-violence incidents; child placed with paternal grandmother and services offered to parents.
Father has long criminal history involving violence and reported problems with anger, impulsivity, and mental health (borderline personality disorder, bipolar, depression, PTSD).
Father inconsistently attended batterers' intervention and other services, was removed from a certified program, briefly re-engaged, then stopped all services by the time of the termination hearing.
Jeopardy order entered late 2012; DHHS filed to terminate father's parental rights in April 2013. Father repeatedly engaged in hostile communications and at times was incarcerated; some medication improved behavior but not sustained progress.
District Court terminated father's parental rights in December 2014 under 22 M.R.S. § 4055(1)(B)(2)(b)(i), (ii), (iv) for inability/unwillingness to alleviate jeopardy, failure to assume responsibility within a reasonable time, and failure to rehabilitate; father appealed.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (DHHS)	Held
Sufficiency of evidence for termination grounds	Termination unsupported by clear and convincing evidence	Record shows mental-health/anger issues, inconsistent service engagement, and ongoing jeopardy	Affirmed: evidence supports statutory grounds for termination
Denial of Rule 60(b) motion to vacate jeopardy order	Jeopardy order was procured by counsel error/coercion; moved to vacate	Motion untimely and not properly before appellate court	Not considered on appeal as father failed to timely appeal that order
Post-termination visitation	Father sought post-termination visitation under §4038-C(3)	Once rights terminated father is no longer a "parent" and cannot seek statutory post-termination visitation; best-interest analysis was proper	Denial affirmed; father cannot obtain visitation as non-parent under that statutory provision
Judicial bias and right to jury trial	Trial judge was biased; father was entitled to jury/different forum	Judge's factual findings were proper; District Court has jurisdiction and due process requires impartial factfinder, not jury	No obvious error: no recusal, no right to jury; refusal to remove to Superior Court affirmed

In re Matthew W., 903 A.2d 333 (Me. 2006) (timeliness and appealability principles for child-protection orders)
In re C.P., 67 A.3d 558 (Me. 2013) (best-interest analysis in termination decisions)
In re David W., 8 A.3d 673 (Me. 2010) (standards for termination and best-interest review)
In re Kaitlyn P., 12 A.3d 50 (Me. 2011) (recusal and review for obvious error when no motion made)
Dionne v. LeClerc, 896 A.2d 923 (Me. 2006) (deference to trial court factual findings)
In re Anthony R., 987 A.2d 532 (Me. 2010) (review of removal to Superior Court for jury trial when not requested)
In re A.M., 55 A.3d 463 (Me. 2012) (due process requires impartial factfinder, not a jury trial in these proceedings)
In re Shane T., 544 A.2d 1295 (Me. 1988) (affirming denial of removal for jury trial in termination proceedings)