AC45891 - In re Daniel D. (Termination of Parental Rights; "The respondent mother, Chrystal P., appeals from the judgments of the trial court terminating her parental rights as to two of her minor children, Daniel D. and James D. The respondent claims that the court improperly (1) admitted into evidence certain documents under the business records exception to the hearsay rule; and (2) concluded that the Department of Children and Families (department) had made reasonable efforts to reunite her with James or that she was unable or unwilling to benefit from reunification efforts. We affirm the judgments of the trial court.")

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AC45534 - In re Cameron H. (Appeal of termination of parental rights pursuant to General Statutes § 17a-112 (j) (3) (B) (ii); "The respondent mother, Joyce F., appeals from the judgments of the trial court terminating her parental rights as to her minor children, Cameron H. and Noah H. (children), pursuant to General Statutes § 17a-112 (j) (3) (B) (ii). On appeal, the respondent claims that the court improperly concluded that (1) the Department of Children and Families (department) made reasonable efforts to reunify her with her children, and that she was unable or unwilling to benefit from the reunification services; and (2) she failed to achieve such a degree of personal rehabilitation as would encourage the belief that, within a reasonable time, considering the age and needs of the children, she could assume a responsible position in their lives. We affirm the judgments of the court.")

• Posted in:
• Juvenile Law,
• Recent Opinions

AC45968 - In re Kharm A. (“The respondent mother, Letishag A., appeals from the judgment of the trial court terminating her parental rights with respect to her minor child, K.1 On appeal, she claims that the court erroneously concluded that the Department of Children and Families (department) had made reasonable efforts at reunification, pursuant to General Statutes § 17a-112 (j) (1). The respondent does not brief a claim that the court erred in its additional conclusion that she was unable or unwilling to benefit from reunification efforts. Because the respondent challenges only one of the two bases for the court’s determination that § 17a-112 (j) (1) had been satisfied, we conclude that the respondent’s appeal is moot.”)

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• Juvenile Law,
• Recent Opinions

AC45719 - In re Amanda C. (“The respondent mother, Christine C. (respondent), appeals from the judgments of the trial court granting the motion of the children’s father, Robert L. (father), to revoke the commitments of their three minor children, A, B, and D; approving the permanency plan requested by the petitioner, the Commissioner of Children and Families (petitioner); reinstating guardianship in the father; and vesting coguardianship in the children’s paternal aunt, S. On appeal, the respondent claims that the trial court improperly determined that the compact does not apply under the circumstances of the present case. We affirm the judgments of the trial court.”)

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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
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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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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
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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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• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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

• Posted in:
• FYI,
• Juvenile Law,
• Legal Research,
• 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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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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.)

• Posted in:
• Juvenile Law,
• Recent Opinions

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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• Juvenile Law,
• Recent Opinions

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.")

• Posted in:
• Juvenile Law,
• Recent Opinions