In re Aisjaha N., 343 Conn. 709

Mother (Jacqueline) has longstanding substance abuse and untreated serious mental health issues; child Aisjaha was placed with maternal grandmother and later adjudicated neglected and committed to DCF custody.
Petitioner (Commissioner of Children and Families) later moved to vest permanent legal guardianship in the maternal grandmother under §46b-129(j); a virtual hearing was held by Microsoft Teams during the COVID-19 pandemic.
After evidence and closing arguments, Jacqueline asked to testify; she testified briefly by audio only (counsel noted she was on the phone and not on video), and no party or guardian ad litem objected when the court asked whether proceeding audio-only was acceptable.
The trial court granted the motion for permanent legal guardianship on clear-and-convincing evidence that termination grounds existed and that guardianship was in the child’s best interests.
Jacqueline appealed, asserting (1) a Fourteenth Amendment due process violation because she was not present via two-way video, and (2) that the court should adopt supervisory rules requiring two-way videoconferencing or waiver before virtual child-protection trials.

Issue	Plaintiff's Argument (Jacqueline)	Defendant's Argument (Commissioner)	Held
Whether failing to ensure the mother appeared by two‑way video at the virtual guardianship hearing violated due process	Mother argues Practice Book §35a‑8 and due process entitled her to at least two‑way video to observe/be observed, confront witnesses, and personally address the factfinder	Commissioner argues she was not excluded, audio testimony is constitutionally permissible, the record is inadequate to review, and objection was waived	Court held claim unreviewable under Golding because the record is inadequate; mother waived any objection to audio‑only testimony by failing to object when court canvassed
Whether the court should invoke supervisory authority to require two‑way videoconferencing (or waiver) before virtual child‑protection trials	Mother asks the court to adopt a rule requiring courts to ensure parties appear by video or knowingly waive that right after a brief canvass	Commissioner notes precedent permitting telephonic testimony (In re Juvenile Appeal), practical access issues (telephone may be only option), and that existing rules suffice	Court declined to exercise supervisory authority: record not sufficiently robust, no showing of a pervasive problem, and trial court took reasonable steps to address technical issues; emphasized importance of ensuring access and proper functioning of technology

State v. Golding, 213 Conn. 233 (standard for appellate review of unpreserved constitutional claims)
In re Yasiel R., 317 Conn. 773 (modification/clarification of Golding review criteria)
In re Juvenile Appeal (Docket No. 10155), 187 Conn. 431 (telephone testimony in parental‑rights proceedings held constitutionally adequate)
Mathews v. Eldridge, 424 U.S. 319 (due process balancing test)
State v. Hill, 307 Conn. 689 (invocation of supervisory authority requires pervasive/significant problem)