In re Christopher C., 232 Conn.App. 104

The Department of Children and Families (petitioner) sought to terminate the respondent father's (Christopher C.) parental rights to his minor child.
The child was adjudicated neglected and committed to state custody shortly after birth; respondent's paternity was established months later.
Respondent moved to transfer guardianship to the child's paternal grandmother in New York, consolidating that request for trial with the termination petition.
At a pretrial conference, respondent orally moved for the trial judge (Torres, J.) to recuse herself, citing her prior involvement with the same proposed guardian in a related but distinct proceeding.
The judge denied the recusal motion, emphasizing case-specific evidence drives her rulings. On the first day of trial, respondent expressly waived any conflict and consented to the judge presiding.
The trial court terminated respondent's parental rights and denied both the transfer of guardianship and out-of-state placement; respondent appealed limited to the denial of recusal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial judge should have recused herself due to prior related case	Respondent argued past involvement in similar matter with same proposed guardian raised concerns of impartiality.	Petitioner argued respondent expressly waived any disqualification claim at trial.	Court held waiver applied—respondent consented, so claim is unreviewable.

State v. Lane, 206 Conn. App. 1 (standard for reviewing trial court's denial of judicial disqualification motions)
In re Christopher C., 134 Conn. App. 464 (standards for judicial impartiality and disqualification)
Allen v. Commissioner of Correction, 167 Conn. App. 868 (waiver of claims on appeal binds party to counsel's trial decisions)
In re Kylie P., 218 Conn. App. 85 (definition and effect of waiver in trial context)