In Re Christopher C., 129 Conn. App. 55

The minor child resided with his mother and her boyfriend prior to involvement by the Commissioner due to unexplained, suspicious injuries.
The Commissioner filed a neglect petition; the mother pled nolo contendere; the respondent father remained silent as a noncustodial parent.
The trial court adjudicated the child neglected because he lived under conditions injurious to his well-being and due to the father's criminal history.
During dispositional proceedings, the paternal grandmother sought guardianship; the mother also sought guardianship, which the court denied.
The court found the grandmother unsuitable because she did not believe in the respondent’s culpability and could be unduly loyal to her son, risking the child’s safety.
The court committed the child to the custody of the Commissioner; the respondent appealed challenging guardianship denial and alleged ineffective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether grandmother was a suitable guardian.	Respondent argues grandmother was suitable.	Grandmother argued suitability; court misapplied standard.	Grandmother unsuitability supported by record.
Whether the trial court’s guardianship denial rested on an improper basis.	Respondent claims lack of non-opinionated basis for denial.	Court considered grandmother’s belief about respondent’s guilt and loyalty risk.	Record supports the court’s basis for denial.
Whether the respondent received ineffective assistance of counsel.	Respondent contends counsel failed to cross-examine, contact witnesses, and allow testimony.	No record showing ineffective performance prejudicial to outcome.	No ineffective-assistance shown; record insufficient to prove prejudice.

In re Kamari C-L., 122 Conn.App. 815 (Conn. App. 2010) (deference to trial findings; standard for sufficiency of evidence)
In re Matthew S., 60 Conn.App. 127 (Conn. App. 2000) (ineffective assistance standard; need prejudice shows)
In re Amanda A., 58 Conn. App. 451 (Conn. App. 2000) (record adequacy requirement for ineffective-assistance claim)