Adoption of Marrek.

CourtMassachusetts Appeals Court
DecidedOctober 3, 2024
Docket23-P-1126
StatusUnpublished

This text of Adoption of Marrek. (Adoption of Marrek.) 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 Marrek., (Mass. Ct. App. 2024).

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

23-P-1126

ADOPTION OF MARREK.1

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a trial that spanned three consecutive days, a

judge of the Juvenile Court found the mother unfit to assume

parental responsibility for her son, Marrek, terminated her

parental rights, and approved the Department of Children and

Families' (department) proposed adoption plan which provided for

adoption by the child's maternal grandmother (grandmother).2 The

trial judge also found that visits with the mother were in the

child's best interests and ordered supervised monthly

posttermination and postadoption visits. Any additional

visitation time was left to the sole discretion of the

1 A pseudonym.

2This appeal arises from a second review and redetermination trial held via Zoom on February 22-24, 2022. Following the first review and redetermination trial, held over nonconsecutive days in the summer of 2019, a trial judge found the mother unfit but did not terminate her parental rights. Previously, the mother stipulated to a finding that she was unfit on October 2, 2018. grandmother, the child's legal custodian. The mother appeals,

arguing that (1) the trial judge's finding of unfitness was

erroneous because it relied on stale evidence and was

unsupported by clear and convincing evidence, and (2) the trial

judge abused her discretion by terminating the mother's parental

rights where guardianship was a viable option and the mother's

positive trajectory demonstrated the likelihood of her future

fitness. We address each of these arguments in turn and,

discerning no error, affirm the decree.

Discussion. 1. Fitness and termination of parental

rights. The mother first argues that the trial judge failed to

properly assess her parental fitness as it existed at the time

of trial but instead relied on stale evidence such as her

previous mental health challenges and her criminal record. The

argument is unavailing.

"To terminate parental rights to a child and to dispense

with consent to adoption, a judge must find by clear and

convincing evidence, based on subsidiary findings proved by at

least a fair preponderance of evidence, that the parent is unfit

to care for the child and that termination is in the child's

best interests." Adoption of Bea, 97 Mass. App. Ct. 416, 421-

422 (2020), quoting Adoption of Jacques, 82 Mass. App. Ct. 601,

606 (2012). "In determining whether the best interests of the

children will be served by issuing a decree dispensing with the

2 need for consent, a court shall consider the ability, capacity,

fitness, and readiness of the child's parents . . ." (quotation

and citation omitted). Adoption of Jacques, supra. "We give

substantial deference to a judge's decision that termination of

a parent's rights is in the best interest of the child, and

reverse only where the findings of fact are clearly erroneous or

where there is a clear error of law or abuse of discretion."

Adoption of Patty, 489 Mass. 630, 637 (2022), quoting Adoption

of Ilona, 459 Mass. 53, 59 (2011).

Importantly, although "a finding of current unfitness

cannot be based on stale information . . . prior history does

have prognostic value." Adoption of Carla, 416 Mass. 510, 517

(1993). Indeed, "[w]here a person's character is itself in

issue, as a parent's character generally is in custody or

adoption cases, courts have usually held that it may be proved

by evidence of specific acts of misconduct bearing on

character."3 Adoption of Irwin, 28 Mass. App. Ct. 41, 43 (1989).

Accordingly, there was no error in the trial judge's

consideration of the mother's past mental health difficulties

3 The mother argues that the trial judge contradicted her posttrial ruling on the mother's motion in limine by including in the findings two incidents from 2002 and 2003, before the mother became a parent. Assuming without deciding that this was an error, leaving aside these two incidents, the trial judge's decree is still fully supported by the record.

3 and criminal history4 as part of the overall assessment of the

mother's fitness so long as that conduct spoke to the mother's

current fitness.5 See id.

Here, sufficient evidence was adduced at trial to support a

finding by clear and convincing evidence that the mother was

unfit. The trial judge considered the mother's ongoing and past

mental health challenges and concluded that she "remain[ed]

mentally unstable in that she [was] unable to demonstrably

ascertain when she [was] experiencing a mental health decline

and continue[d] to minimize her past behavior/signs of

decompensation."

To reach this conclusion, the trial judge relied in part on

testimony from a department social worker, who testified that in

4 The mother also argues that the trial judge erroneously considered dispositions on the mother's CARI contrary to the judge's ruling that the mother's CARI would be admissible but "limited to CWOFs and convictions." However, the trial judge's findings regarding the mother's criminal history largely relied on exhibits 9 and 10, which are records from the Holyoke and Northampton police departments. The two instances in which the trial judge considered dispositions on the mother's CARI that were not CWOFs or convictions related to two restraining orders, one that was independently supported by the mother's testimony and another that was supported by police department records.

5 The mother submits that the trial judge could only properly consider evidence after the first review and redetermination trial that concluded on July 10, 2019, where the judge found the mother to be unfit but did not terminate her parental rights. However, "a judge may rely upon a parent's past conduct . . . so long as that evidence is not the sole basis for the judge's unfitness determination." Adoption of Luc, 484 Mass. 139, 145 (2020).

4 April 2018 she had to cancel a parent-child visit when the

mother grew angry with her after she asked the mother if she was

taking her medication. When the social worker attempted to

speak with the mother further, the mother "charged" at her but

was prevented from taking further action by another staff

member. The social worker also testified she observed the

mother in a "manic" state on multiple occasions from January

2018 through August 2018, a period of time when the mother would

visit the department office without an appointment and would

voluntarily divulge previous traumatic experiences to department

employees.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Adoption of Irwin
545 N.E.2d 1193 (Massachusetts Appeals Court, 1989)
Custody of Eleanor
610 N.E.2d 938 (Massachusetts Supreme Judicial Court, 1993)
Adoption of Carla
623 N.E.2d 1118 (Massachusetts Supreme Judicial Court, 1993)
Adoption of Hugo
700 N.E.2d 516 (Massachusetts Supreme Judicial Court, 1998)
Adoption of Ilona
944 N.E.2d 115 (Massachusetts Supreme Judicial Court, 2011)
Adoption of Dora
754 N.E.2d 720 (Massachusetts Appeals Court, 2001)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Adoption of Jacques
976 N.E.2d 814 (Massachusetts Appeals Court, 2012)
Hugo P. v. George P.
526 U.S. 1034 (Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Adoption of Marrek., Counsel Stack Legal Research, https://law.counselstack.com/opinion/adoption-of-marrek-massappct-2024.