In re Adoption of Maisie

The mother and father appeal from decrees terminating their parental rights, as well as the posttermination visitation order. We remand for clarification regarding the termination of parental rights and the visitation order.

1. Sufficiency of the evidence regarding the father's unfitness.2 The father argues that struggling with opiates and violating the law are not sufficient evidence of unfitness.

A decision to terminate parental rights calls for a two-step analysis. See G. L. c. 210, § 3 ; Adoption of Nancy, 443 Mass. 512, 515 (2005). First, the judge must find, by clear and convincing…