In re Meena H., 177 A.3d 1276

Two children, Meena and Blayne, were the subject of long-running Department of Health and Human Services involvement beginning before 2016; they had previously been in custody, were reunified with Mother in 2015, then removed again in January 2016.
Mother has a longstanding schizoaffective disorder with repeated psychiatric hospitalizations and episodic noncompliance with medication; when symptomatic she becomes paranoid and unable to care for the children.
After the 2016 removal, children exhibited significant trauma: Meena is highly anxious and parentified; Blayne is angry, defiant, and diagnosed with an adjustment disorder.
Father (Blayne’s father) had a history of domestic violence, limited engagement with reunification services, incarcerated during the case, and lacked insight into the children’s needs or the impact of Mother’s illness.
The District Court found by clear and convincing evidence that both parents could not protect or provide for the children within a time reasonably calculated to meet their needs and that termination was in the children’s best interests; parental rights were terminated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported finding of parental unfitness under 22 M.R.S. § 4055(l)(B)(2)(b)	Mother argued evidence was insufficient to show unfitness	State argued clear-and-convincing proof of inability to protect/meet needs within reasonable time	Court affirmed: findings supported unfitness determination
Whether termination was in children’s best interests	Mother contested sufficiency of evidence only as to unfitness (did not contest best-interest finding on appeal)	State argued termination would allow healing and permanency the parents could not provide	Court held termination was proper and not an abuse of discretion
Whether parents could achieve stability within a reasonable time given mental health and domestic-violence histories	Mother pointed to recent stability and work on services	Father pointed to limited participation but did not raise arguable issues on appeal	Court found patterns of relapse and lack of insight made timely safe reunification unlikely
Adequacy of trial court fact-finding (denial of requests for additional findings)	Mother sought further findings under M.R. Civ. P. 52(b) and 59(e)	State maintained existing findings were sufficient and additional proposed findings were irrelevant	Mother did not challenge denial on appeal; court’s existing findings deemed sufficient

In re Logan M., 155 A.3d 430 (Me. 2017) (standard of review for factual findings in parental-unfitness determinations)
In re Arturo G., 175 A.3d 91 (Me. 2017) (court’s discretion in best-interest determinations in termination proceedings)