In re Zarianna C., 177 A.3d 1270

This case involves termination of the father’s parental rights to three daughters (Zarianna, Zariyah, Zaylah) after longstanding Department of Health and Human Services involvement dating to 2011; the mother consented to termination and is not an appellant.
Multiple prior child-protection episodes: a 2011 case (dismissed after reunification), a 2014 case (dismissed in 2015 with supervised-visits order), and the present case filed November 6, 2015. The children have lived most of their lives with the same foster parents.
The Jeopardy Order cited the father’s extensive substance-abuse history, prior domestic violence, criminal activity and incarcerations, and that he had never been primary caregiver.
The father made some recent efforts (substance-abuse counseling, Drug Court attendance, enrollment in a batterer’s intervention program, limited parenting classes) but had inconsistent engagement, missed appointments, and positive drug/alcohol tests after purported sobriety.
The court found by clear and convincing evidence that the father was unwilling or unable to protect the children or take responsibility within a time reasonably calculated to meet their needs, and that termination (with adoption as permanency plan) served the children’s best interests because they were bonded to foster parents and needed permanency now.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the father is legally unfit (unable/unwilling to protect children and take responsibility within a reasonable time)	DHHS: Father’s long history of substance abuse, criminality, domestic violence, inconsistent services, and failed sobriety demonstrate unfitness	Father: Has made progress—attended programs, claims sobriety, enrolled in interventions—so termination is premature	Court: Held father unfit by clear and convincing evidence under 22 M.R.S. §4055(l)(B)(2)(b)(i)-(ii) due to inconsistent sobriety, inadequate engagement, and history of jeopardy
Whether termination is in the children’s best interests (permanency)	DHHS/foster parents: Children are strongly bonded to foster parents, have lived with them most of their lives, and need immediate permanency	Father: Continued progress argues for more time for reunification efforts	Court: Exercising discretion, held termination and adoption plan are in children’s best interests given need for prompt permanency and substantial attachment to foster family

In re Logan M., 155 A.3d 430 (Me. 2017) (standard of review for factual findings in parental termination appeals)
In re Caleb M., 159 A.3d 345 (Me. 2017) (deference to trial court’s best-interest determination and abuse-of-discretion review)
In re Thomas H., 889 A.2d 297 (Me. 2005) (precedent on termination standards and best-interest analysis)