In re M.E., 131 A.3d 898

This is the second appeal in a Maine child-protection case in which the District Court terminated the father’s parental rights to M.E.; the father previously lost an appeal affirming jeopardy findings.
The father consistently disputed the severity and cause of the child’s medical needs, refused to follow medical instructions, and did not comply with rehabilitation or reunification services.
The father displayed disruptive, aggressive, and threatening behavior at medical appointments, team meetings, supervised visits, and in court; providers found him impossible to work with.
The child improved in foster care, is bonded to the foster parents, requires special feeding care (including a gastrostomy tube), and the foster parents wish to adopt.
The father did not attend the December 4–5, 2014 termination hearing; the court held the evidentiary hearing in his absence with counsel cross-examining witnesses, later allowed the father to testify when he appeared on December 8, and entered judgment terminating parental rights on December 11.
The father raised due process, notice, counsel-preservation, and prejudice claims (including claims of national-origin and language-based bias); the court found extensive interpreter and translation accommodations and no evidence of prejudice.

Issue	Father’s Argument	State’s Argument	Held
Whether sufficient evidence supports termination for unwillingness or inability to protect the child from jeopardy	The termination lacked sufficient evidence and violated due process	Record shows father refused to follow medical instructions, failed rehabilitation, and endangered child	Court affirmed: sufficient evidence; one ground of unfitness is enough to support termination
Whether termination was in the child’s best interest	Father argued process failures and prejudice undermined best-interest finding	State argued child’s health improved in foster care and foster parents met needs	Court affirmed: termination is in child’s best interest
Whether father suffered discrimination or language/cultural prejudice	Father claimed bias based on national origin/immigration and culture	Court and State showed provision of paid Russian interpreters and translated documents; no record support for bias claim	Court rejected prejudice claim; record shows accommodations were provided
Whether procedural defects (notice, default, counsel issues) invalidated judgment	Father asserted default and other procedural errors deprived due process	Court found father was notified, had counsel present at hearing who cross-examined witnesses, and was later allowed to testify; post-judgment motions denied properly	Court held procedural claims unpersuasive and judgment stands

In re M.E., 97 A.3d 1082 (Me. 2014) (prior appeal affirming jeopardy finding)
In re A.H., 77 A.3d 1012 (Me. 2013) (only one ground of parental unfitness required for termination)
In re M.B., 65 A.3d 1260 (Me. 2013) (standard for parental-unfitness sufficiency review)
In re Thomas H., 889 A.2d 297 (Me. 2005) (best-interest determination standard)
Samsara Mem’l Trust v. Kelly, Remmel & Zimmerman, 102 A.3d 757 (Me. 2014) (recusal/forfeiture principle for failure to timely seek disqualification)
In re Jon N., 754 A.2d 346 (Me. 2000) (disapproval of hyperbolic, abusive briefing)
In re I.S., 121 A.3d 105 (Me. 2015) (rejecting unsupported claims that diagnosis alone justified termination)