In re Jeffrey E.
Supreme Judicial Court of Maine
557 A.2d 954 (Me. 1989)
Linda E. and James E. (defendants) routinely failed to provide their infant son Jeffrey with medication and therapy for his recurring pneumonia despite repeated hospitalizations, prompting Maine's Department of Human Services (the Department) (plaintiff) to temporarily remove him into foster care, where he thrived. After three written service agreements addressing the family's health, discipline, structure, and Jeffrey's developmental stimulation went unmet, the Department discontinued reunification efforts and petitioned to terminate both parents' rights; the trial court granted the petition, and Linda and James appealed, arguing insufficient evidence supported it.
Whether a trial court may terminate parental rights based on clear and convincing evidence that the child's well-being was placed in jeopardy by the parents' inability to meet the child's special medical and developmental needs.