In re Adoption of Posy

*748From his home in Guatemala, the father sought to obtain custody of his two daughters who were placed in foster care after the death of their mother in the United States. The father could not take immediate custody of the children because he had been deported earlier.2 After a one-day trial, at which the father was necessarily absent due to his immigration status, a *749Probate and Family Court judge issued decrees terminating the father's parental rights. In finding the father to be an unfit parent, the judge characterized him as having "abandoned" the children. She also found that he had "a…