In re Children of Jamie P.

2020 ME 85
CourtSupreme Judicial Court of Maine
DecidedJune 9, 2020
StatusPublished
Cited by1 cases

This text of 2020 ME 85 (In re Children of Jamie P.) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Children of Jamie P., 2020 ME 85 (Me. 2020).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2020 ME 85 Docket: Ken-19-502 Submitted On Briefs: May 28, 2020 Decided: June 9, 2020

Panel: GORMAN, JABAR, HUMPHREY, HORTON, and CONNORS, JJ.

IN RE CHILDREN OF JAMIE P.

PER CURIAM

[¶1] A mother and father appeal from a consolidated judgment of the

District Court (Augusta, Rushlau, J.) terminating their parental rights to their

three children. See 22 M.R.S. § 4055(1)(B)(2)(a), (b)(i)-(ii) (2020). Both

parents argue that the Department of Health and Human Services did not

present sufficient evidence upon which the trial court could find that they are

parentally unfit and contend that the court abused its discretion in finding that

termination was in the children’s best interests. The father also contends that

the trial court abused its discretion by engaging in improper sua sponte

questioning of witnesses pursuant to Maine Rule of Evidence 614. We affirm

the judgment.

I. BACKGROUND

[¶2] In February 2019, the Department petitioned to terminate the

parents’ parental rights as to all three children. See 22 M.R.S. § 4052 (2020). 2

The trial court (Rushlau, J.) held a two-day hearing, from July 11 to July 12, 2019,

on the Department’s petition. Both parents were present at the hearing and

represented by counsel. See 22 M.R.S. § 4054 (2020).

[¶3] In a judgment dated November 21, 2019, the trial court terminated

the parents’ parental rights with regard to all three children. See

§ 4055(1)(B)(2)(a), (b)(i)-(ii). The trial court found by clear and convincing

evidence that each parent is unwilling or unable to protect the children from

jeopardy and that these circumstances are unlikely change within a time which

is reasonably calculated to meet the children’s needs, and that each parent has

been unwilling or unable to take responsibility for the children within a time

which is reasonably calculated to meet the children’s needs. See

§ 4055(1)(B)(2)(b)(i)-(ii). The trial court also found by clear and convincing

evidence that termination of the parents’ parental rights is in the children’s best

interests. See § 4055(1)(B)(2)(a). Its findings were supported by competent

evidence in the record. In re Child of Carl D., 2019 ME 67, ¶ 4, 207 A.3d 1202.

[¶4] The trial court’s judgment contained the following findings

regarding the mother’s fitness:

After [the twins] were born in 2015 . . . there were a series of events which led both to legal proceedings and made the family situation unstable. On August 14, 2015, [the father] filed a complaint for protection from abuse . . . . He claimed that [the mother] had 3

physically abused him and threatened to kill both him and the children. He received a temporary and then a final protection order. Although the final order was originally to remain in effect until September 4, 2017, the complaint was dismissed, and the order terminated on [the father’s] motion on May 13, 2016. Four months later [the father] returned to the same court and filed another complaint for protection from abuse . . . . He once again described domestic violence by [the mother], including violence in the presence of the children. [The father] once again received a protection order. Once again [the father] returned to court within a few months and moved for dismissal of the complaint. . . . Meanwhile [the mother] had been prosecuted for the criminal conduct committed against [the father] . . . . She ultimately pleaded guilty to Domestic Violence Terrorizing . . . .

DHHS was involved with the family between 2015 and 2017. The primary purpose of their involvement was apparently to ensure that [the father] and the children were not living with [the mother]. . . . DHHS began a more significant involvement in June 2017. [A caseworker] visited the . . . home of [a family member] . . . and found that [the parents] were living there with all three children. . . . During the visit, [the father] told the caseworker about [the mother’s] violence against him . . . .

During the [termination] hearing [the father] confirmed . . . that [the mother] had engaged in repeated violence against him throughout this entire period. He also confirmed that she had threatened to kill the children. . . . It is clear that [the mother] engaged in significant domestic violence against [the father] for several years and that when the children are in [the father’s] presence they are exposed to this violence.

....

. . . DHHS’s Rehabilitation and Reunification Plan signed by [the mother] on January 19, 2018, described a series of steps [the mother] needed to take in order to make progress toward reunification. One step was to complete a batterers intervention 4

program (BIP). Other steps included being employed, having stable housing, and developing an effective mental health treatment and medication program. While [the mother] has been working to some extent on all these issues, she has made relatively little progress. She began a BIP in Lewiston but . . . failed to complete the program. . . . Her housing situation was erratic for many months, and included “couch surfing,” camping out in a tent for a period of time, and a stay in a homeless shelter. . . . She worked for brief periods for several different employers. . . . [The mother] engaged with [a counselor] at Kennebec Behavioral Health for many months . . . . However, [the mother’s] progress was regularly disrupted for a variety of reasons. . . . [The counselor] saw no progress at all in one important area, which was [the mother] gaining insight on how to avoid conflict with others . . . .

DHHS arranged for [the mother] to have a trial placement with the twins in August of 2018. . . . A few days later [the mother] drove her car with the twins as passengers. They were in ordinary seat belts. [The mother] failed to secure them in child safety seats. . . . [The mother] drove through a stop sign . . . and collided with another vehicle. Both vehicles were damaged and [the mother’s] was [totaled]. The twins had medical evaluations and some treatment but fortunately neither child was seriously injured. However, the emotional effect of the crash on the twins, and indirectly on [the older child], was significant.

[¶5] The court’s supported evidentiary findings as to the father’s

parental fitness are as follows:

[The father] was the target of multiple acts of physically violent behavior by [the mother] over a period of years. [The mother] also threatened violence against both him and against the children. Initially he acted responsibly to protect the children when he obtained a protection order in 2015. Several months later he had the protection order terminated. His reason was that it was too difficult for him to take care of the children on his own. Within a short time, [the mother] engaged in more violent behavior. [The 5

father] again acted responsibly by obtaining a second protection order. Once again, he had the order terminated. Once again, he allowed [the mother] to have access to the children. He was then, once again, the target of [the mother’s] violent behavior . . . .

. . . [I]n June 2017, [the father] told the DHHS caseworker that he was overwhelmed by the responsibilities of being a parent of three children. . . . He terminated both protection orders and allowed [the mother] access to the children because he was incapable of providing appropriate care on his own. The testimony of [a family member] showed that as early as 2015 she and other family members were caring for the children for various periods of time . . . .

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In re Children of Jamie P.
2020 ME 85 (Supreme Judicial Court of Maine, 2020)

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