ADOPTION OF TAHI (And a Companion Case).

CourtMassachusetts Appeals Court
DecidedApril 30, 2025
Docket24-P-0663
StatusUnpublished

This text of ADOPTION OF TAHI (And a Companion Case). (ADOPTION OF TAHI (And a Companion Case).) 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 TAHI (And a Companion Case)., (Mass. Ct. App. 2025).

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

24-P-663

ADOPTION OF TAHI (and a companion case1).

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

Following a review and redetermination trial that spanned

eight nonconsecutive days between April and November of 2023, a

judge of the Juvenile Court found the mother unfit to assume

parental responsibility for her children, Tahi and Ava,

terminated her parental rights, and approved the proposed

adoption plan of the Department of Children and Families

(department) to place the children with their foster mother.2 In

her findings of facts and conclusions of law, the trial judge

also found that an order of visitation between the children and

the mother was not in the children's best interests. The mother

now appeals, arguing: (1) the trial judge's decision rested on

1 Adoption of Ava. The children's names are pseudonyms.

2On September 9, 2019, the mother had stipulated to and was found unfit to parent Tahi and Ava. The department was then given "permanent" custody of the children. an erroneous finding that the mother had an active substance

abuse problem at the end of trial, and any evidence of the

mother's substance abuse was stale and could not support a

finding of future unfitness; (2) the trial judge abused her

discretion in finding that termination of the mother's parental

rights was in the children's best interests; and (3) the trial

judge erred in refusing to order posttermination and

postadoption visitation with Ava. We affirm.

Discussion. 1. Mother's fitness. The mother 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 relative to her previous substance abuse issues. The

argument is predicated on factual findings in the judge's

decision indicating that the mother used drugs in the summer of

2022, as well as the judge's consideration of the mother's

"ability to maintain a sober lifestyle" and the mother's

"ongoing substance abuse," which were incorporated within the

judge's ultimate unfitness determination.

We begin by first noting that in finding the mother unfit,

the trial judge considered numerous factors, which the mother

does not challenge, alongside the mother's substance abuse

history, including the mother's housing instability, involvement

in domestic violence relationships, and inability to

consistently engage in treatment or to meaningfully engage with

2 the department. As discussed infra, these factors alone were

sufficient to support an unfitness determination.3 Therefore,

even assuming without deciding that the judge mistakenly and

thus erroneously concluded that the mother was using drugs as

recently as the summer of 2022, or had an "ongoing" substance

abuse issue,4 any error was harmless where, as discussed below,

3 The mother argues that the language in the judge's decision that "the paramount issue in this case is Mother's issues with substance abuse" indicates that the judge terminated the mother's rights primarily because of her substance abuse issues. However, later in her decision the judge wrote "Mother's substance abuse and inconsistent treatment is of paramount concern and contributes to her parental unfitness" (emphasis supplied). The judge also used the word "paramount" on two other occasions where she did not reference the mother's substance abuse issues. Therefore, we do not read the judge's use of the word "paramount" to mean "sole" or "exclusive." Additionally, the mother's substance abuse was clearly of "paramount" concern in this case, as it was a primary cause of her children's removal.

4 For example, the mother specifically takes issue with findings of fact, numbers 166 and 173, in the judge's decision. In finding number 166, the judge made an inference that "Mother was struggling with her substance abuse in the summer of 2022" because of her failure to provide certified drug screens in July and August of 2022, as well as her prior testimony that "the 'entire' reason she was not communicating with the Department during certain periods was because she was using drugs during those times." However, the mother's life was considerably disrupted due to domestic violence in the summer of 2022, and the "periods" the mother was referring to in her previous testimony were from "the initiation of the case" over three years prior "and the few months that followed." Therefore, the mother argues that the judge's inference was inaccurate and improper.

Finding number 173 concludes that the mother informed a victim advocate that she had been sober twelve months as of June

3 the "judge's conclusion that the mother was unfit was clearly

and convincingly supported by the judge's [other] subsidiary

findings." Adoption of Bea, 97 Mass. App. Ct. 416, 426 (2020).

Furthermore, 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." 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 entire history of substance abuse

especially where the mother's substance abuse was a central

issue in the initial removal of her children, and evidence was

adduced at trial that the mother's substance abuse remained an

ongoing concern, at least as of 2022. See Adoption of Anton, 72

Mass. App. Ct. 667, 676 (2008) (finding evidence of drug abuse

relevant to parent's "willingness, competence, and availability

to provide care"). Notably, the mother worked with a recovery

support specialist during February and March of 2022 and

2023. However, the advocate's testimony was that the mother informed her that she had been twelve months sober in June of 2022.

4 discussed entering "long-term sober living," a recommendation

that the judge found the mother did not "embrace." The mother

also failed to provide the department with certified drug

screens in July, August, and September of 2022, albeit during a

time when she was moving and was the victim of domestic

violence. To be sure, the mother has engaged in various

substance abuse treatment programs since 2019. However, her

treatment has been sporadic and inconsistent, and as of late

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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 Willow
745 N.E.2d 330 (Massachusetts Supreme Judicial Court, 2001)
Care & Protection of Georgette
785 N.E.2d 356 (Massachusetts Supreme Judicial Court, 2003)
Adoption of Nancy
822 N.E.2d 1179 (Massachusetts Supreme Judicial Court, 2005)
Adoption of Ilona
944 N.E.2d 115 (Massachusetts Supreme Judicial Court, 2011)
Adoption of Terrence
787 N.E.2d 572 (Massachusetts Appeals Court, 2003)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Adoption of Anton
893 N.E.2d 436 (Massachusetts Appeals Court, 2008)
Adoption of Jacques
976 N.E.2d 814 (Massachusetts Appeals Court, 2012)

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ADOPTION OF TAHI (And a Companion Case)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/adoption-of-tahi-and-a-companion-case-massappct-2025.