In Re Christopher C.
134 Conn. App. 473
| Conn. App. Ct. | 2012Background
- Respondent mother appeals from trial court judgments terminating her parental rights to Christopher C. and Allyson L.
- Petitioner department of children and families sought termination after long history of abuse, neglect, and safety concerns.
- Children were adjudicated neglected and placed in petitioner’s custody; since 2010 they resided together in a preadoptive foster home.
- Adjudicatory phase found the department made reasonable reunification efforts and respondent failed to achieve personal rehabilitation.
- Respondent challenged these findings, arguing reunification efforts were not reasonable and rehabilitation was not properly weighed.
- Appellate court affirmed, holding department efforts were reasonable and respondent failed to rehabilitate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the department made reasonable reunification efforts | Department showed substantial, targeted efforts and provided steps for reunification. | Department did not assist in ending relationship with Allyson's father and failed to engage mental health counseling. | Not clearly erroneous; department's efforts were reasonable. |
| Whether respondent was unwilling to benefit from reunification efforts | Respondent refused/refused to participate in services and ignored multiple referrals. | Respondent disputes characterization and argues not all steps were required. | Not clearly erroneous; respondent unwilling to participate. |
| Whether respondent achieved sufficient personal rehabilitation | Respondent failed to address mental health and substance abuse and did not protect children. | Respondent argues rehabilitation could be realized with additional time and services. | Not clearly erroneous; respondent failed to rehabilitate within reasonable time. |
Key Cases Cited
- In re G.S., 117 Conn.App. 710, 980 A.2d 935 (2009) (reasonable reunification efforts defined; 'reasonable' is not 'everything possible')
- In re Sole S., 119 Conn.App. 187, 986 A.2d 351 (2010) (appellate review deferential to trial court findings in termination proceedings)
- In re Tremaine C., 117 Conn.App. 590, 980 A.2d 330 (2009) (standards for rehabilitation adequacy and reasonable time given child’s needs)
- In re Krystal J., 88 Conn.App. 311, 869 A.2d 706 (2005) (parent not entitled to reunification where she refuses to participate)
- In re Antony B., 54 Conn.App. 463, 735 A.2d 893 (1999) (participation requirement for reunification efforts and rehabilitation considerations)