Summary
The Maine Supreme Judicial Court vacated a judgment terminating Jennifer B.’s parental rights to five children. The court held that testimony concerning three drug-screen results was inadmissible hearsay because it lacked an adequate foundation, and that the erroneous admission of the June and July results was not harmless given the trial court’s reliance on them in finding parental unfitness. The case was remanded for further proceedings, with the court also noting concerns about the trial court’s best-interests analysis.
Court
Supreme Judicial Court of Maine
Jurisdiction
Maine Supreme Judicial Court
Decision date
May 21, 2026
Docket number
Pen-24-575
Disposition
vacated
Questions Presented
- Whether the District Court erred by admitting testimony about the January, June, and July drug-screen results when the testimony was based on statements in a file compiled by third persons and lacked an adequate foundation.
- Whether the error in admitting the June and July drug-screen testimony was harmless.
- Whether the admission of the August drug-screen result was erroneous.
Holdings
- The testimony about the June and July drug screens was inadmissible hearsay because the program director testified to statements in a record compiled by third persons for the truth of the matter asserted, without the underlying documentation or evidence establishing the testing circumstances, method, or sample handling.
- The January drug-screen result was inadmissible hearsay for the same reason as the June and July results, although the unobjected-to admission ordinarily would be reviewed for obvious error.
- The District Court did not err in admitting the August drug-screen result.
- The error in admitting the June and July drug-screen testimony was not harmless.
Court Document
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