In re Danyellah S.-C., 143 A.3d 698

Mother of four with long history of DCF involvement for substance abuse, domestic violence, inadequate supervision; children adjudicated neglected and eventually committed to DCF custody.
Mother failed to comply with reunification steps: missed services, resisted substance testing/treatment, lacked stable housing/income, and visited children only twice after commitment.
Court-appointed counsel (Peter Catania) represented mother since 2013; trial on termination occurred July 2015 with judgments rendered November 20, 2015 terminating parental rights under § 17a-112(j).
Midtrial, after a recess, the mother abruptly asked the court to discharge her attorney when her father appeared and sought to serve as a witness; no substantive reason for discharge was stated.
Trial court denied the midtrial request, found no substantial reason or exceptional circumstance to replace appointed counsel, and concluded the denial did not abuse discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying mother's midtrial request to discharge court‑appointed counsel	Mother argued the court should have inquired further into her request and allowed new counsel	State argued mother gave no substantial reason; court was not required to probe a single unsupported outburst during trial	Court held no error: absent a seemingly substantial reason, the court need not inquire or replace counsel; denial was within discretion
Whether a constitutional right under Conn. Const. art. I, § 10, to appointed effective counsel alters analysis	Mother suggested a state constitutional right to effective assistance in TPR proceedings	State relied on statutory right to counsel and existing precedents; constitutional ruling unnecessary	Court declined to decide constitutional question because statutory precedent sufficed; outcome unchanged even assuming such a right

State v. Gonzalez, 205 Conn. 673 (1987) (trial court need only inquire into requests to discharge counsel when defendant voices a seemingly substantial complaint)
State v. Drakeford, 202 Conn. 75 (1987) (no reversible error where defendant gave no substantial reason for replacing appointed counsel)
State v. Robinson, 227 Conn. 711 (1993) (trial court must evaluate substantial complaints about court-appointed counsel; timing of complaint is critical)
In re Alexander V., 223 Conn. 557 (1992) (statutory right to appointed counsel in termination proceedings)
State v. Anonymous, 179 Conn. 155 (1979) (state law guarantees right to effective assistance of counsel)
In re Jonathan M., 255 Conn. 208 (2001) (discussion of constitutional claims to effective assistance in TPR context)
In re Yasiel R., 317 Conn. 773 (2015) (requirements for advising respondent in termination proceedings)