The Appeals Court considered a multi‑part family‑law appeal involving the Department of Children and Families and the mother of the subject child.

Eric Bail, counsel for the mother, told the panel that the case centered on the mother's mental‑health diagnosis (bipolar disorder) and the trial court’s prediction that she would decompensate in the future. Bail emphasized that the record showed substantial improvement by the time of trial, engagement with treatment providers, dismissed earlier care and protection proceedings, and ongoing housing and treatment plans; he argued the judge abused discretion by terminating parental rights based on projected future unfitness rather than the evidence of stabilization.

Alan Campbell, counsel for the child (the child’s representative), limited his argument to a visitation condition incorporated in the post‑termination order. He said a clause allowing the adoptive parent discretion to end visitation if the mother missed two consecutive visits would nullify the very contact the court had found “gentle, loving, and child‑centered.” Campbell urged that the judge’s own finding that continued contact was in the child’s best interest made the blanket two‑miss rule unreasonable.

Claire Gilchrist, arguing for DCF, urged the court to affirm the termination and the visitation safeguards, describing a nearly four‑year pattern of instability in Massachusetts, prior hospitalizations and housing loss, disrupted foster/pre‑adoptive placements and trial‑period disruptions; she said the judge reasonably found termination necessary to protect the child's permanency and that narrowly tailored post‑termination and post‑adoption visitation limits were justified to prevent further disruption.

The panel questioned counsel about whether and how a final adoption proceeding could revisit any provisional visitation order and pressed on the record about the factual bases for the judge's credibility determinations. The court took the matter under advisement.