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Juvenile Law

Juvenile Law Appellate Court Slip Opinions

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5244

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5242


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.")



Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5215

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5192

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5184

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5146

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.)


Juvenile Law Appellate Court Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5145

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5126

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.")


Juvenile Law Appellate Court Slip Opinion

   by Booth, George

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5115

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.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5075

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)).

We further conclude, however, that the form of the court's judgment is improper. The court should have dismissed, rather than denied, the motion to open and set aside. Accordingly, we reverse the judgment and remand the case to the trial court with direction to dismiss the motion to open and set aside.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5072

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.")


Juvenile Law Supreme and Appellate Court Slip Opinions

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5056

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.")


Juvenile Law Supreme Court Slip Opinions

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5044

SC20614 - In re Annessa J. ("In her appeal, the respondent mother, Valerie H., claims that the Appellate Court improperly rejected her unpreserved claim that the trial court had violated her rights under article fifth, § 1, and article first, § 10, of the Connecticut constitution by conducting the termination of parental rights trial virtually, via Microsoft Teams, rather than in person. She also claims that the Appellate Court incorrectly determined that the record was inadequate to review her unpreserved claim that she was denied her right to physically confront the witnesses against her at the virtual trial, in violation of the due process clause of the fourteenth amendment to the United States constitution. In the cross appeal, the petitioner, the Commissioner of Children and Families, claims that the Appellate Court improperly expanded the standard for deciding motions for posttermination visitation and improperly reversed the trial court's rulings on those motions for failing to comply with that new standard.")

SC20612 - In re Aisjaha N. ("This appeal is one of the companion cases to In re Annessa J., 343 Conn. 642, ___ A.3d ___ (2022), which we also decide today. The respondent mother, Jacqueline H., appeals from the decision of the trial court, which vested permanent legal guardianship of Jacqueline's minor child, Aisjaha N., in a relative, pursuant to General Statutes § 46b-129 (j) (6). On appeal, Jacqueline claims that she was denied due process of law when the trial court failed to ensure that she appeared by two-way video technology at a virtual trial, conducted via Microsoft Teams, on the motion for permanent legal guardianship. Alternatively, Jacqueline asks this court to reverse the decision of the trial court pursuant to our supervisory authority over the administration of justice. Specifically, she asks this court to adopt a procedural rule requiring that a trial court, before conducting a virtual trial in a child protection case, ensure that the parties either appear by two-way videoconferencing technology or waive the right to do so, after a brief canvass. We affirm the decision of the trial court.")

SC20603, SC20604 - In re Vada V. ("These appeals are companion cases to In re Annessa J., 343 Conn. 642, ___ A.3d ___ (2022), and In re Aisjaha N., 343 Conn. 709, ___ A.3d ___ (2022), which we also decide today. The respondents, Sebastian V. and Samantha C., appeal from the judgments of the trial court, which terminated their parental rights pursuant to General Statutes § 17a-112 (j). On appeal, the respondents raise three unpreserved constitutional claims relating to the virtual nature of the termination of parental rights trial. Specifically, the respondents contend that the trial court violated their rights under article first, § 10, and article fifth, § 1, of the Connecticut constitution by conducting the termination of parental rights trial virtually, via Microsoft Teams, rather than in person. They also contend that they were denied the right to physically confront the witnesses against them at the virtual trial, in violation of the due process clause of the fourteenth amendment to the United States constitution. Finally, the respondents contend that their constitutional rights were violated when the state required them to participate in the virtual trial without providing them with an electronic device and internet connection that allowed them to appear before the trial court in the same manner as if they were in a courtroom. We affirm the judgments of the trial court.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5022

AC44926 - In re Madison C. ("Following the termination of her parental rights as to her three children, the respondent, Patricia K., filed a petition for a new trial (petition), pursuant to General Statutes § 52-270. In response, the Commissioner of Children and Families (commissioner) filed a motion to strike for failure to state a claim upon which relief can be granted, which the court ultimately granted and rendered judgment thereon. The respondent appeals from that judgment, claiming that the court improperly granted the motion to strike her petition because she had alleged newly discovered evidence that, if known during the pendency of her trial, likely would have altered the outcome. Because the facts averred in the respondent's petition do not constitute newly discovered evidence within the meaning of § 52-270, we affirm the judgment of the trial court.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=4989

AC45087 - In re Marcquan C. ("The respondent mother, Monica C., appeals from the judgment of the trial court denying her motion to revoke the commitment of her minor child, Marcquan C., to the custody of the petitioner, the Commissioner of Children and Families (commissioner). On appeal, the respondent contends that the court erred in finding that cause for commitment continued to exist. We affirm the judgment of the trial court.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=4987

AC45012 - In re Rabia K. (Mootness; Vacatur; "In this neglect proceeding, the respondent mother, Michelle K., appeals from the judgment of the trial court adjudicating Rabia K., the respondent’s minor daughter, neglected and committing her to the care and custody of the petitioner, the Commissioner of Children and Families. On appeal, the respondent claims that the court improperly found that (1) Rabia had been neglected and (2) the Department of Children and Families (department) made reasonable efforts to prevent Rabia’s removal."

---

"Accordingly, we dismiss this appeal as moot and vacate the judgment of the court.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=4958

AC44918, AC44923 - In re Teagan K.-O. ("In these two appeals, the respondent parents appeal from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating their parental rights with respect to their minor child, Teagan K.-O. (Teagan). In Docket No. AC 44918, the respondent mother claims that the trial court lacked the statutory authority to terminate her parental rights under General Statutes § 17a-112 because Teagan was not in the custody of the petitioner pursuant to General Statutes § 46b-129. Specifically, she argues that the fact that our Supreme Court ordered that the neglect petition filed with respect to Teagan be dismissed vitiated the statutory predicate for the order of temporary custody over Teagan that had been granted to the petitioner under § 46b-129. In Docket No. AC 44923, the respondent father claims that the trial court lacked jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), General Statutes § 46b-115 et seq., to adjudicate the petition for termination of parental rights because (1) the order of temporary custody was not a final custody determination for purposes of establishing jurisdiction under the UCCJEA, and (2) there is no mechanism by which the order of temporary custody could become a final custody determination. We affirm the judgment of the trial court.")


Juvenile Law Appellate Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=4947

AC44831 - In re Ryder M. ("The respondent father, Phillip M., appeals from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating his parental rights as to his minor son, Ryder M., on the ground that he failed to achieve a sufficient degree of personal rehabilitation pursuant to General Statutes § 17a-112 (j) (3) (B) (i). On appeal, the respondent claims that the court improperly determined that (1) the Department of Children and Families (department) made reasonable efforts to reunify him with Ryder, (2) he failed to rehabilitate sufficiently, and (3) termination of his parental rights was in Ryder’s best interest. We affirm the judgment of the trial court.")


Juvenile Law Supreme Court Slip Opinion

   by Roy, Christopher

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=4920

SC20624 - In re Ivory W. ("The respondent claims that the trial court's denial of her motion for a continuance violated her due process right to present a defense to the termination of her parental rights under the federal and state constitutions. The respondent further claims that, if this court determines that the denial of her motion for a continuance was constitutional, the denial was an abuse of discretion. Finally, the respondent claims that, if this court determines that the denial of her motion for a continuance was neither unconstitutional nor an abuse of discretion, this court should exercise its supervisory authority over the administration of justice to direct our trial courts to grant motions for a continuance of termination of parental rights proceedings whenever related criminal proceedings against the parent are pending. We reject the respondent's claims and affirm the judgments of the trial court.")