In re Max M.

Summary

The Rhode Island Supreme Court affirmed a Family Court decree terminating Eric M.’s parental rights to his son, Max M. The court held that clear and convincing evidence supported findings of parental unfitness and that the Department of Children, Youth and Families made reasonable efforts toward reunification. The decision discusses parental due process rights, compliance with case-plan services, visitation, and reunification efforts.

Holdings

1. The Family Court did not clearly err in finding Eric unfit to parent Max. A parent's refusal to cooperate with DCYF case planning and services, combined with inconsistent visitation, failure to support or plan for the child, and lack of interest in reunification, constituted clear and convincing evidence of unfitness.
2. DCYF made reasonable efforts to strengthen the parent-child relationship and reunify Eric with Max.
3. Before parental rights may be terminated, the state must establish parental unfitness by clear and convincing evidence, and the court must consider reasonable reunification efforts and the child's best interests.

Questions Presented

1. Whether the Family Court clearly erred in finding, by clear and convincing evidence, that Eric was unfit to parent Max.
2. Whether DCYF made reasonable efforts to strengthen the parent-child relationship and reunify Eric with Max.
3. Whether the termination of Eric's parental rights was otherwise properly affirmed, including the child's best interests.

Disposition

affirmed