In Re Christopher C., 134 Conn. App. 464

The respondent father verbally and physically abused the child's mother; the parents separated in May 2009.
The respondent is a registered sex offender and cannot have unsupervised contact with the child under his probation terms.
The petitioner took custody of the child on August 22, 2009 after the child was treated for multiple facial injuries consistent with physical abuse.
A neglect petition was filed on August 26, 2009; the court adjudicated the child neglected on May 7, 2010 and committed him to the petitioner's custody on October 6, 2010.
The petitioner filed a petition to terminate the respondent's parental rights on November 19, 2010; trial occurred with Judge Foley; the court issued a memorandum of decision on June 9, 2011 and entered judgment terminating parental rights.
The court found, by clear and convincing evidence, that the department made reasonable efforts to reunify and that the respondent failed to achieve sufficient personal rehabilitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable reunification efforts	Department made reasonable reunification efforts.	Respondent challenges the sufficiency of reunification efforts.	moot; independent finding that respondent cannot benefit from reunification suffices
Personal rehabilitation	Respondent failed to achieve sufficient rehabilitation within a reasonable time.	Respondent argues rehabilitation was possible with continued efforts.	not clearly erroneous; substantial evidence of substance abuse, mental health issues, and criminal history
Judicial disqualification	No disqualification due to lack of demonstrated bias; prior sentencing does not show impartiality issues.	Judge Foley was biased due to prior sentencing, warranting recusal.	no merit; no objective doubt of impartiality; proper denial of motion to disqualify

In re Jorden R., 293 Conn. 539 (2009) (two alternative grounds for § 17a-112(j)(1) reunification proof)
In re Alison M., 127 Conn. App. 197 (2011) (mootness and alternative grounds in reunification analysis)
McKenna v. Delente, 123 Conn. App. 137 (2010) (review of motions to disqualify for judicial impartiality)