Adoption of Wyck.

CourtMassachusetts Appeals Court
DecidedApril 22, 2026
Docket25-P-0486
StatusUnpublished

This text of Adoption of Wyck. (Adoption of Wyck.) 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 Wyck., (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-486

ADOPTION OF WYCK. 1

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The father appeals from a 2024 decree issued by a judge of

the Juvenile Court terminating the father's parental rights as

to Wyck. 2 We affirm the decree.

Background. Wyck was removed from his mother's care when

he was approximately nine months old and was one week away from

turning four years old by the time the decree issued. The

father was incarcerated for the entirety of Wyck's life through

trial, having pleaded guilty to assault and battery on the

mother while she was pregnant with Wyck. As a result, Wyck has

1 A pseudonym.

2The mother was found unfit for reasons unrelated to the father, and her rights were also terminated. The mother did not file a notice of appeal, and she unfortunately died in February 2025. never been in the father's care and has interacted with the

father only during supervised visits.

The judge found the father unfit and terminated his

parental rights to Wyck based primarily on the father's history

of violent behavior, particularly his "ongoing and persistent

pattern" of intimate partner violence and his "inability to

refrain from criminal activity in time not incarcerated," 3

creating "a significant physical and emotional danger to

[Wyck]." The judge also considered that Wyck was not

meaningfully bonded to the father but was "extremely bonded"

with his preadoptive foster mother, and that the father had not

engaged fully with the services required to address the concerns

about his ability to parent Wyck.

Discussion. On appeal, the father does not contest his

unfitness at the time of trial; rather, he argues that his

unfitness was merely temporary. In particular, he argues that,

because his incarceration prevented him from accessing many of

the services set forth in his action plan, the Department of

Children and Families (department) did not make reasonable

3 The father has been charged with thirty-nine violent crimes and numerous nonviolent offenses. He was also the defendant in nine different c. 209A abuse prevention orders obtained by four different women (including both mothers of the father's older children) and has been charged with eleven violations of such orders. He was convicted and sentenced to from five to seven years in State prison for armed robbery and a stabbing.

2 efforts at reunification, and the judge did not properly account

for the father's limited access to such services in finding his

unfitness likely to continue indefinitely. Given these special

circumstances, the father argues, the termination of his

parental rights amounted to an abuse of discretion.

We review "to determine whether the judge's findings were

clearly erroneous and whether they proved parental unfitness by

clear and convincing evidence." Custody of Eleanor, 414 Mass.

795, 802 (1993). "[S]ubsidiary evidentiary findings need only

be proved by a fair preponderance of the evidence." Care &

Protection of Laura, 414 Mass. 788, 793 (1993). "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 Ilona, 459 Mass. 53, 59 (2011).

1. Reasonable efforts. The father argues that the

department failed to make reasonable efforts at reunification

because it did not account for what services father actually had

access to while incarcerated, resulting in the father's action

plan including tasks that he was unable to complete. He argues

that the judge's erroneous finding that the department made

reasonable efforts warrants vacating the termination decree. We

are unconvinced.

3 First, the father's reasonable efforts argument is waived

as it was not sufficiently raised to the department or the

Juvenile Court judge. See Adoption of Mattis, 106 Mass. App.

Ct. 548, 549-550 (2026) (reasonable efforts claims subject to

ordinary waiver rules). The father did not at any time argue

that the department should have done more to provide him with

services while in prison, nor did he seek to delay the

termination proceedings until he was able to avail himself of

services that he was not able to access through the correctional

facility. Although the department was arguably on notice that

its action plan was not tasking father with "accessible,

available, and culturally appropriate services" 4 (citation

omitted), Care & Protection of Rashida, 488 Mass. 217, 219

(2021), the father did not at any time suggest what additional

or different efforts the department could and should have made

but did not. 5

4 The department's reports repeatedly state, "Due to [the father's] incarceration, [his] participation in his action plan is limited," indicating its awareness that at least some services were not available to the father.

5 The father argues, correctly, that 110 Code Mass. Regs. § 1.10 (2008) "recognizes the special efforts required" when a parent is incarcerated. While the listed requirements that the department provide regular visitation and hold case conferences at the correctional facility may not be exhaustive, the requirement of "special efforts" is still limited to those that are "reasonable." See id. Where the father has not argued that the department should have made particular additional or

4 Nor did the father make any effort to raise the issue to a

judge, such as by filing an "abuse of discretion" motion,

raising the issue at a case conference, or arguing the issue at

trial. 6 See Adoption of West, 97 Mass. App. Ct. 238, 242-243

(2020). To the contrary, in August 2023 -- over a year before

the review and redetermination trial -- a judge determined that

the department had made reasonable efforts at reunification, and

the father waived appeal. The father's reasonable efforts

argument is, therefore, waived.

Second, even if the father's argument had been preserved

and assuming arguendo that the department did fail to make

reasonable efforts, such circumstances would "not preclude the

court from making any appropriate order conducive to the child's

best interest," including an order terminating the father's

parental rights. Adoption of Ilona, 459 Mass. at 61, quoting

G. L. c. 119, § 29C. Because we conclude, infra, that the judge

alternative efforts, we have no basis to conclude that the regulation was not satisfied.

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Related

Care and Protection of Laura
610 N.E.2d 934 (Massachusetts Supreme Judicial Court, 1993)
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Adoption of Gillian
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Chace v. Curran
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Adoption of Cadence
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Cite This Page — Counsel Stack

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