In Re Chevol G.
125 Conn. App. 618
| Conn. App. Ct. | 2010Background
- The Department of Children and Families sought termination of parental rights of Chevol G., Trinity G., and Lazarus G. and the trial court held hearings.
- The trial court found that the department made reasonable efforts to reunify the children with the respondent under § 17a-112(j).
- The court also found the respondent had not achieved a sufficient degree of personal rehabilitation as required by § 17a-112.
- The court concluded termination of parental rights was in the best interests of the children, enumerating seven statutory factors.
- The respondent mother appealed, challenging the court’s findings on reasonable efforts, personal rehabilitation, and best interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonable efforts toward reunification | Department made reasonable efforts, including case management and services. | Department failed to follow up on offered services and did not reasonably assist reunification. | Not clearly erroneous; efforts deemed reasonable. |
| Personal rehabilitation | Respondent failed to achieve the degree of rehabilitation that would enable future stable parental responsibility. | Respondent showed some progress and engagement with services indicating potential rehabilitation. | Not clearly erroneous; lack of sufficient rehabilitation established. |
| Best interests of the children | Termination is in the children's best interests, considering seven statutory factors and the children’s needs. | Termination is not in the children's best interests given some progress and potential for reunification. | Not clearly erroneous; termination warranted in light of history and evidence. |
Key Cases Cited
- In re Gabrielle M., 118 Conn.App. 374 (2009) (standard for review of termination findings; evidence supported)
- In re Katia M., 124 Conn.App. 650 (2010) (reasonableness of reunification efforts; clear and convincing standard)
- In re Kaitlyn A., 118 Conn.App. 14 (2009) (personal rehabilitation analysis relative to child's needs)
- In re Trevon G., 109 Conn.App. 782 (2008) (rehabilitation not dispositive; observed parenting deficiencies)
- In re Johnson R., 121 Conn.App. 464 (2010) (seven-factor best interests framework for termination)
- In re Alexander C., 262 Conn.2d 308 (2003) (standard of review and factual sufficiency in TPR cases)
- In re Melody L., 290 Conn. 131 (2009) (scrupulous standard of factual review; concurring view rejected by court)