In re Child of Shai F.

2020 ME 67 (2020) · Supreme Judicial Court of Maine · May 12, 2020 · No. Cum-19-482

Summary

The Maine Supreme Judicial Court affirmed a District Court judgment terminating Shai F.'s parental rights. The court held that the record supported findings of parental unfitness based on jeopardy, failure to take responsibility, and failure to make a good-faith effort toward reunification, as well as the finding that termination was in the child's best interest. The court also concluded that an erroneous factual finding regarding visitation was harmless.

Holdings

  1. The record supported the District Court's findings, by clear and convincing evidence, that the mother was unable or unwilling to protect the child from jeopardy, unable or unwilling to take responsibility for the child within a reasonable time, and failed to make a good-faith effort to reunify.
  2. The District Court's supported findings established by clear and convincing evidence that termination of the mother's parental rights was in the child's best interest.
  3. The erroneous finding that the mother's weekly visits had been suspended since May 1, 2019 was harmless and did not require reversal.

Questions Presented

  1. Whether the record supported the District Court's findings that the mother was an unfit parent under 22 M.R.S. § 4055(1)(B)(2)(b).
  2. Whether clear and convincing evidence established that termination of the mother's parental rights was in the child's best interest under 22 M.R.S. § 4055(1)(B)(2)(a).
  3. Whether an erroneous finding concerning the suspension of the mother's visitation required reversal.

Disposition

affirmed

Cases Cited (3)

  • In re M.C., 2014 ME 128, ¶¶ 6-7, 104 A.3d 139(followed)
  • In re Child of Stephenie F., 2018 ME 163, ¶ 2 n.2, 198 A.3d 203(followed)
  • In re Child of Nathaniel B., 2019 ME 120, ¶ 5, 212 A.3d 863(followed)

Cited In (0)

No citing cases on record yet.

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