Adoption of Fitch.

CourtMassachusetts Appeals Court
DecidedJanuary 2, 2026
Docket25-P-0388
StatusUnpublished

This text of Adoption of Fitch. (Adoption of Fitch.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adoption of Fitch., (Mass. Ct. App. 2026).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

25-P-388

ADOPTION OF FITCH.1

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The father contests the judge's post-trial determination

that the father was unfit and the termination of his parental

rights to his son, Fitch, age six. We affirm.

Background. We summarize the trial judge's findings of

fact, supplemented by uncontroverted evidence from the record,

reserving certain facts for later discussion. Fitch was born in

May 2019, the third child of his parents, who lost custody of

both older children.2 Fitch was born substance exposed. The

Department of Children and Families (department) filed its first

petition in February 2021. The petition was based on the

mother's arrest for a controlled substance offense, missed

1 The child's name is a pseudonym.

2The mother, who was also named in the care and protection petition, consented to Fitch's adoption during the pendency of the trial. She is not a party to this appeal. medical appointments for Fitch, and the family's history with

the department. The parents were not living together at the

time. Fitch was allowed to remain with the mother subject to

conditions, including a condition barring the father from being

an unsupervised or sole caretaker of Fitch. Because of the

father's record of domestic abuse and ongoing criminal

engagement, the mother had a safety plan that limited the

father's ability to visit with Fitch.

The Department drafted an action plan for the family

effective April 13, 2021, to October 13, 2021. The father

avoided contact and failed to engage with the department through

May, July, September, and most of October 2021. He did not

have consistent visits or contact with Fitch from May through at

least December 2021. The father neither completed the

recommended action plan items nor engaged with the department to

update his action plan until after he was incarcerated in April

2022.

In late October 2021, the father agreed to meet with the

department and, at the time, reported that he was living in a

shelter. He had also lacked housing during the preceding

months. In November, however, the father failed to appear for

the scheduled meeting with a department worker and, as a result,

the department remained unable to conduct the father's

2 assessment. He stayed out of contact with the department

through at least March 2022; in June of that year, the

department met with the father at a house of correction, where

he had been incarcerated since April 2022. It is unclear from

the findings how the department became aware that he was

incarcerated.

In July 2022 the department contacted the jail to schedule

virtual visits between Fitch and the father. But, days later,

the father was transferred to the New York prison system to

serve a three-year sentence and remained there when trial began.

Once the father was incarcerated, he had very little contact

with Fitch. Virtual visits were unsuccessful because they

required that the mother (who had custody of Fitch) pay a fee

and supervise the visits, both of which she could not or would

not do. Fitch had telephone contact with the father between May

and July 2022, and the father sent letters and photos to Fitch.

As of December 2022, the department had no contact with the

father, who remained incarcerated in an unknown New York

facility on unknown charges. Until June 2023, the department

did not know where the father was in prison. In June 2023, the

department took custody of Fitch after learning that the

mother's abusive partner was living with her, and that he and

the mother were misusing controlled substances. Fitch has been

3 in department custody since then. As of October 2023, the

father had not visited with Fitch for "a long time" before

Fitch's second removal.

The department regained contact with the father in August

2023 when, through counsel, he requested an update on Fitch's

placement and put forward his cousin in Virginia as a potential

adoptive resource for Fitch. The department initiated the

process through the Interstate Compact on Placement of Children

(ICPC), and the paternal cousin was eventually approved as an

adoptive resource for Fitch; Fitch has been in Virginia since

July 2024.

In addition to the charges for which the father was

incarcerated in New York, he has an extensive criminal history

in Massachusetts. He has been incarcerated for offenses

including larceny, assault and battery (including assault with a

dangerous weapon), intimidation, and drug charges. He was also

named in four abuse prevention orders in which the mother was

the plaintiff.

The judge concluded that the father had "no meaningful bond

with the child. He did not make any inquiries as to the child's

wellbeing while Fitch was in substitute placement. The court

[did] not credit any assertion that [the father] made

meaningful efforts to engage with the Department, noting that

4 [the father] had ample time and access to his counselors at the

facilities where he was held." The judge determined that the

father was "largely absent from the child's life."

The judge further concluded that the father exhibited

questionable judgment about what was in Fitch's best interests -

- he engaged in domestic violence toward the mother, resulting

in the entry of multiple 209A orders to protect the mother, as

well as the safety plan noted above, and acknowledged that the

mother's partner had exposed Fitch to both domestic violence and

substance misuse, but still believed that Fitch could safely be

with the mother and supported that placement.

Discussion. The father asserts that the department failed

to make reasonable efforts to reunite him with Fitch and that

this failure tainted the judge's best interests analysis. We

are not persuaded.3

When reviewing a judge's decision to terminate parental

rights, we "afford deference to the judge's assessment of the

weight of the evidence and the credibility of the witnesses, as

3 The department asserts that the father waived the reasonable efforts argument by failing to raise it at or before trial. See Adoption of Yalena, 100 Mass. App. Ct. 542, 554 (2021) (department must have "opportunity to make accommodations while the case is pending"). We agree that the father could and should have more forcefully made and preserved this argument, but we exercise our discretion to consider it. See, e.g., Adoption of West, 97 Mass. App. Ct. 238, 242, 245 (2020).

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ADOPTION OF YALENA.
100 Mass. App. Ct. 542 (Massachusetts Appeals Court, 2021)

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Bluebook (online)
Adoption of Fitch., Counsel Stack Legal Research, https://law.counselstack.com/opinion/adoption-of-fitch-massappct-2026.