In Re Thomas D.

[¶ 1] In this parental rights termination action, we examine the effect that the failure to establish a rehabilitation and reunification plan for a parent has on the District Court’s later consideration of a termination petition brought by the Department of Human Services. The mother and father of Thomas D. appeal from the judgment of the District Court (Biddeford, Kennedy, J.) terminating their parental rights pursuant to 22 M.R.S.A. § 4055 (2004). The parents challenge several aspects of the judgment, including the sufficiency of the evidence establishing their parental unfitness and the…