In Re Child of Karen J.

Summary

The court vacated the termination of Karen J.'s parental rights because the trial court placed substantial reliance on her inability to relocate from New Mexico to Maine, despite finding that she had gone above and beyond the reunification-plan requirements. The court held that the practical inability to obtain affordable housing in Maine, without more, could not establish parental unfitness by clear and convincing evidence. Because unfitness was not established, the court did not reach the child's best interests and remanded for further proceedings and express findings.