AC45575 - In re Autumn O. ("The respondent mother, Michelle O., appeals from the judgments of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights with respect to two of her minor children, Autumn O. and Joshua W., pursuant to General Statutes § 17a-112 (j). On appeal, the respondent claims that the court improperly determined that (1) the respondent was unable or unwilling to benefit from reunification services, (2) the respondent had failed to achieve a sufficient degree of personal rehabilitation, and (3) it was in the best interests of the minor children to terminate her parental rights. We conclude that the appeal is moot as to the first claim and dismiss that portion of the appeal. We otherwise affirm the judgments of the trial court.")

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AC45549 - In re Anthony S. ("The respondent mother, Agnes W., appeals from the judgment of the trial court terminating her parental rights with respect to her minor child, Anthony S. On appeal, the respondent claims that the trial court improperly determined that (1) the Department of Children and Families (department) made reasonable efforts toward reunification between the respondent and Anthony, (2) the respondent had failed to rehabilitate to such a degree as to reasonably encourage a belief that she could assume a responsible position in the life of her child, and (3) the termination of the respondent's parental rights was in the best interest of Anthony. We affirm the judgment of the trial court.")

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AC45434 - In re Kylie P. ("The respondent mother, Isheika P., appeals from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights with respect to her minor child, Kylie P. (Kylie). On appeal, the respondent claims that the trial court (1) violated her "right to a fair trial by an impartial tribunal . . . as guaranteed by the due process clause to the United States constitution" when it purportedly ordered Kylie's attorney to call an additional witness at trial after the close of evidence, (2) was precluded from finding that she failed to rehabilitate because the Department of Children and Families (department) improperly interfered with her parent-child relationship by threatening to remove her youngest child if she returned to Connecticut, (3) erred in concluding that the department made reasonable efforts to reunify her with Kylie, (4) erred in concluding that the department was not required to make reasonable efforts pursuant to General Statutes § 17a-111b (a) (2) because it already had approved a permanency plan for termination of parental rights, and (5) erred in finding that she failed to rehabilitate because there was insufficient evidence on which to make that finding. We affirm the judgment of the trial court.")

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AC45686 - In re Nevaeh G.-M. ("The respondent Kimberly G. appeals from the judgments of the trial court, rendered in favor of the petitioner, the Commissioner of Children and Families, adjudicating the respondent's three children—Nevaeh G.-M., Melinda G.-M., and Jackson A.-R.—neglected and uncared for and terminating her parental rights as to all three children. On appeal, the respondent claims that (1) there was insufficient evidence to support the court's determination that the petitioner had proven by clear and convincing evidence that the respondent had failed to rehabilitate in accordance with General Statutes § 17a-112 (j) (3) (B) (i), and (2) the court improperly (a) failed to order a court-appointed psychological evaluator to disclose to the respondent certain testing materials on which the evaluator had based her opinion, (b) refused the respondent's request for a Porter hearing regarding the evaluator's testing methods, and (c) admitted the evaluator's written report over a hearsay objection. We conclude that the evidence was sufficient to support the court's judgments terminating the parental rights of the respondent on the statutory ground of failure to rehabilitate and that the claimed evidentiary errors, even if established, were harmless. Accordingly, we affirm the judgments of the court.")

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AC45693 - In re Eric M. ("The respondent father, Eric S., appeals from the judgment of the trial court rendered for the petitioner, the Commissioner of Children and Families, terminating his parental rights to his minor son, Eric M. (Eric), on the grounds that he failed to achieve a sufficient degree of personal rehabilitation pursuant to General Statutes § 17a-112 (j) (3) (B) (i) and that there is no ongoing parent-child relationship pursuant to § 17a-112 (j) (3) (D). On appeal, the respondent claims that the court improperly (1) determined that the interference exception did not apply to preclude the petitioner from relying on the no ongoing parent-child relationship ground for termination and (2) found that the respondent had not rehabilitated such that he could assume a responsible position in the life of the child. We affirm the judgment of the trial court.")

AC45551 - In re Isabella Q. ("The respondent father, Michael Q., appeals from the judgment of the trial court, rendered in favor of the petitioner, the Commissioner of Children and Families, terminating his parental rights with respect to his daughter, Isabella Q. On appeal, the respondent claims that the court improperly concluded that the petitioner established by clear and convincing evidence that (1) pursuant to General Statutes § 17a-112 (j) (1), the respondent was unable or unwilling to benefit from reunification services, (2) the respondent failed to rehabilitate in accordance with § 17a-112 (j) (3) (B) (i), and (3) termination of the respondent's parental rights was in Isabella's best interests pursuant to § 17a-112 (j) (2). We affirm the judgment of the trial court.")

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AC45269 - In re K. M. ("The respondent father, Michael M., appeals from the judgments of the trial court in which the court denied in part the respondent's motion for supplemental orders regarding therapeutic visitation, denied the respondent's motion to enforce compliance with court orders, and granted the motion of the petitioner, the Commissioner of Children and Families, to suspend the respondent's visitation with his minor children, A and B. The respondent's sole claim on appeal is that the trial court erred in vacating prior visitation orders and entering new visitation orders. We affirm the judgments of the trial court.")

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AC45357 - In re A'vion A. (The respondent mother appeals from the judgments of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights as to A'vion, Aaliyah, and Azra, her minor children. On appeal, the respondent claims that the court improperly (1) denied her October 2, 2019 motion to compel the Department of Children and Families (department) to provide additional reunification services, (2) concluded that she failed to achieve the requisite degree of personal rehabilitation required by General Statutes § 17a-112 (j) (3) (B) with respect to Azra, and (3) determined that the department made reasonable efforts to reunify her with the minor children pursuant to § 17a-112 (j) (1).We conclude that the appeal is moot as to the final claim and dismiss that portion of the appeal. We otherwise affirm the judgments of the trial court.")

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AC45427 - In re G. H. ("The respondent mother, Jessica M. H., appeals from the judgments of the trial court terminating her parental rights with respect to her minor children, G. H. (G) and N. H. (N). On appeal, the respondent claims that the trial court (1) improperly concluded that she had failed to rehabilitate to such a degree as to reasonably encourage a belief that she could assume a responsible position in the lives of her children, (2) made inconsistent statements in its memorandum of decision that require reversal, and (3) improperly concluded that the termination of her parental rights was in the best interests of the children. We affirm the judgments of the trial court.")

AC45183, AC45199, AC45369 - In re Maliyah M. ("These three appeals present the same legal claim and involve similar, though unrelated, factual and procedural histories. In each appeal, the respondent parent appeals from the judgment of the trial court terminating his or her parental rights. On appeal, each respondent asserts the same claim—that the court 'denied the respondent the due process of law under the fourteenth amendment to the United States constitution' when it conducted the termination of parental rights trial, either in whole or in part, virtually, via Microsoft Teams, without first holding an evidentiary hearing to determine whether there was a compelling need for virtual testimony.

After the respondents filed their principal briefs in each appeal, this court granted the unopposed motions filed by the petitioner, the Commissioner of Children and Families, requesting that her brief be due thirty days after our Supreme Court issued its decisions in In re Annessa J., 343 Conn. 642, ___ A.3d ___ (2022), and its companion cases, In re Vada V., 343 Conn. 730, 275 A.3d 1172 (2022), and In re Aisjaha N., 343 Conn. 709, 275 A.3d 1181 (2022), which involved claims similar to the claim in the present cases. Our Supreme Court issued those decisions on June 20, 2022, and we now conclude that In re Annessa J. is dispositive of the issue in the present appeals. Accordingly, we affirm the judgments of the trial courts.")

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AC45241 - In re Aubrey K. ("The respondent mother, Victoria K., appeals from the judgment of the trial court, rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights with respect to her minor daughter, Aubrey K. (Aubrey), on the ground that the respondent’s acts of parental commission or omission denied Aubrey the care necessary for her well-being pursuant to General Statutes § 17a-112 (j) (3) (C).2 The court also found that, although the Department of Children and Families (department) had made reasonable efforts to reunify the respondent with Aubrey, the respondent was unable or unwilling to benefit from reunification efforts; see General Statutes § 17a-112 (j) (1); and that termination of the respondent’s parental rights was in Aubrey’s best interest. See General Statutes § 17a-112 (j) (2). On appeal, the respondent’s single claim is that there was insufficient evidence for the trial court to find that the termination of her parental rights was in Aubrey’s best interest. We affirm the judgment of the trial court.")

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The 2022 edition of our research guide on Rights of Minors has been posted to our research guides webpage.

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• Self-Help

AC45388 - In re Lil'Patrick T. ("The respondent father, Lil’Patrick T., Sr., appeals from the judgment of the trial court terminating his parental rights with respect to his minor child, P. On appeal, the respondent claims that the trial court (1) incorrectly concluded that he failed to achieve a sufficient degree of personal rehabilitation as would encourage the belief that, within a reasonable time, he could assume a responsible position in the life of P, (2) incorrectly determined that termination of his parental rights was in the best interest of P and (3) failed to canvass him adequately concerning his right to testify on his own behalf. We affirm the judgment of the trial court.")

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AC44973 - In re Faith D.-A. ("The respondent mother, Shanequa A., appeals from the judgment of the trial court terminating her parental rights with respect to her minor child, Faith D.-A. On appeal, the respondent claims that she was denied due process of law and equal protection of the law under the fourteenth amendment to the United States constitution because ‘the state compelled her to participate in a virtual trial to terminate her parental rights without providing her with an electronic device that allowed her to appear before the court in the same manner as if she were on trial in a courtroom.’ We affirm the judgment of the trial court.")

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AC44992 - In re Takie O. ("The respondent father, Takie O., Sr., appeals from the judgment of the trial court terminating his parental rights with respect to his minor child, Takie O. (child). On appeal, the respondent claims that he was denied the right to physically confront the witnesses against him at the virtual trial, conducted via Microsoft Teams, in violation of the due process clause of the fourteenth amendment to the United States constitution. We affirm the judgment of the trial court.")

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AC45124, AC45156 - In re Lillyanne D. (In these two appeals, the respondent mother, Chrystal P., and the respondent father, William D., appeal from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating their parental rights as to their minor child, Richard D. In Docket No. AC 45124, the respondent mother claims that the trial court improperly admitted into evidence two documents under the residual exception to the rule against hearsay. In Docket No. AC 45156, the respondent father claims that the court improperly concluded that (1) the Department of Children and Families (department) had made reasonable efforts to reunify him with Richard or, alternatively, that he was unwilling and unable to benefit from those reunification efforts, (2) he had failed to achieve the requisite degree of rehabilitation required by General Statutes § 17a-112 (j), and (3) it would be in Richard’s best interest to terminate his parental rights. We affirm the judgment of the trial court.)

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AC45210 - Rek v. Pettit ("Before this court are two motions for review filed by the plaintiffs. The first motion, filed on April 4, 2022, asks this court to review and reverse the court's March 8, 2022 order determining that there is no automatic appellate stay in effect. The second motion, filed on April 21, 2022, asks this court to review and reverse the court's March 22, 2022 order denying their request for a discretionary stay. On the first motion for review, we conclude that the underlying orders are visitation orders that are not automatically stayed pursuant to Practice Book § 61-11 (c).On the second motion for review, we conclude that the court did not abuse its broad discretion in denying the plaintiffs' request for a discretionary stay only insofar as the court ordered the parties to engage with a new therapist for the purposes of facilitating visitation; we reach a different conclusion with respect to the court's order suspending Caleb's contact with his long-term personal counselor. We therefore grant the plaintiffs' April 4, 2022 motion for review, but deny the relief requested therein, and grant the April 21, 2022 motion for review, and grant, in part, the relief requested therein.")

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AC45058 - In re Delilah G. ("The respondent mother, Amanda L., appeals from the judgment of the trial court granting the petition of the petitioner father, Juan G., to terminate her parental rights with respect to her minor daughter, Delilah G. On appeal, the respondent claims that the court improperly determined that (1) there was no ongoing parent-child relationship between her and Delilah pursuant to General Statutes § 45a-717 (g) (2) (C) and (2) she had abandoned Delilah pursuant to § 45a-717 (g) (2) (A). We affirm the judgment of the trial court.")

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AC45026 - In re Katia V. (Termination of parental rights; Claim of violation of mother’s rights under ADA; "The respondent mother, Karen V., appeals from the judgment of the trial court terminating her parental rights with respect to her minor daughter, Katia V. (Katia). On appeal, the respondent claims that (1) the Department of Children and Families (department) and the court violated her rights under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. § 12101 et seq. (2018), (2) the court erred by denying her motion to bifurcate the adjudicatory and dispositional portions of the termination proceedings, and (3) the court erred by denying her motion to sequester certain witnesses. We affirm the judgment of the trial court.")

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AC45092 - In re Omar I. ("The self-represented respondent, Ammar I., whose parental rights had been terminated in a prior proceeding, appeals from the judgment of the trial court denying his motion to open and set aside the adoptions of his three minor children, Omar I., Safiyah I. and Muneer I., on the ground that he lacked standing under In re Zen T., 165 Conn. App. 245, 252–54, 138 A.3d 469, cert. denied, 322 Conn. 905, 138 A.3d 934 (2016), cert. denied sub nom. Heather S. v. Connecticut Dept. of Children and Families, 580 U.S. 1135, 137 S. Ct. 1111, 197 L. Ed. 2d 214 (2017). On appeal, the respondent claims that he did not receive timely and proper notice of the court's July 27, 2021 ruling regarding his amended petition for a new trial so that the court incorrectly determined that he lacked standing to challenge the adoption decrees issued on August 20, 2021. We conclude that, because the court correctly determined that notice of its July 27, 2021 decision had been sent properly to the respondent the same date as its issuance, the respondent's parental rights had been adjudicated fully and fairly prior to the issuance of the adoption decrees. Thus, the court properly determined that the respondent lacked standing to challenge the adoption decrees. See In re Zen T., supra, 252–54; see also Practice Book § 7-5 ('[t]he clerk shall give notice, by mail or by electronic delivery, to the attorneys of record and self-represented parties' (emphasis added)).

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AC45111 - In re Paulo T. ("The respondent father, Horace W., appeals from the granting of the motion for reinstatement of guardianship rights filed by the petitioner mother, Mae T., with respect to their minor child, Paulo T. On appeal, the respondent claims that the court (1) improperly applied a presumption that reinstatement of the petitioner's guardianship rights was in the best interests of Paulo, (2) erroneously found that the factors that had led to the removal of the petitioner's guardianship rights had been resolved satisfactorily, (3) erroneously found that reinstatement of the petitioner's guardianship rights was in the best interests of Paulo, and (4) improperly dismissed the respondent's motion to open the judgment. We disagree with these claims and, accordingly, affirm the judgment of the trial court.")

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SC20671 - In re Amias I. ("The respondent mother, Jennifer S., appeals from the judgments of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights as to her three children, Anaya I., Amias I., and Adelyn I., due to her failure to achieve a sufficient degree of personal rehabilitation that would encourage the belief that, within a reasonable time, considering the ages and needs of her children, she could assume a responsible role in their lives. The respondent claims that, in addition to their statutory right to conflict free counsel established by the legislature in General Statutes § 46b-129a (2) (A), this court should hold that her children also had a procedural due process right to such counsel under the state and federal constitutions, and that the trial court violated this right by failing to inquire into whether the attorney appointed to represent them, Dana E. Clark, had a conflict of interest due to the children's conflicting goals regarding reunification. Alternatively, the respondent seeks reversal of the judgments pursuant to the plain error doctrine. We conclude that we need not decide whether the respondent's children had a constitutional—as opposed to only a statutory—right to conflict free counsel because, even if they did, it is apparent that any violation of such a right was harmless error. We also decline the respondent's request to apply the plain error doctrine. Accordingly, we affirm the judgments of the trial court.")

AC44814 - In re Alizabeth L.-T. ("The respondent father, Benjamin L., appeals from the judgments of the trial court sustaining ex parte orders granting temporary custody of his minor children, Alizabeth L.-T., Tanisha L., and Alyson L.-T., to the petitioner, the Commissioner of Children and Families. The respondent father raises several evidentiary claims on appeal, including that, at the contested hearing, the court improperly (1) admitted certain hearsay statements of the children under a statutory exception to the hearsay rule codified in General Statutes § 46b-129 (g), and (2) admitted hearsay statements made by Alizabeth during a forensic interview under the medical diagnosis or treatment exception to the hearsay rule. See Conn. Code Evid. § 8-3 (5). We agree with both claims and conclude that these evidentiary errors, considered together, were not harmless because, without the improperly admitted hearsay testimony and exhibits, it is likely that the outcome of the hearing would have been different. Accordingly, we reverse the judgments of the court and remand the case for a new contested hearing.")

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