In re Denzel W., 225 Conn.App. 354

The case involves the termination of the respondent mother's parental rights as to her minor children, Denzel W. and Ariel W., following a long history of domestic violence between her and the children's father, Timothy W.
The Department of Children and Families became involved with the family after multiple reports of child neglect and exposure to intimate partner violence over several years.
A stabbing incident in 2019, in which Timothy W. stabbed the respondent mother in the presence of the children, led to their removal from her care and the issuance of a protective order.
Despite the protective order, the mother continued contact with Timothy, including attempts to conceal their ongoing relationship from authorities.
The mother participated in various services and programs but demonstrated only minimal progress, continued to minimize the impact of domestic violence on the children, and failed to maintain a safe, stable environment.
The trial court, after hearing evidence from social workers, a psychologist, law enforcement, and others, found by clear and convincing evidence that the mother failed to rehabilitate and that termination was in the children's best interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court improperly shift the burden of proof on rehabilitation?	The mother argued the language used by the court placed the burden on her to prove rehabilitation.	The state argued the full decision showed the court placed the burden properly on the state, as required.	The court did not shift the burden; correct standard applied.
Was there sufficient evidence the mother had failed to rehabilitate?	The mother claimed domestic violence had ceased after 2019 and there was no hard evidence of continued contact after 2021.	The state countered that ongoing contact, concealment, and lack of insight showed failure to rehabilitate.	Sufficient evidence supported failure to rehabilitate.
Did the court make adequate findings regarding the mother's participation in services?	The mother claimed she completed services and that this should show rehabilitation.	The state argued mere participation was insufficient given ongoing issues and violations.	The court's findings on her engagement and failures were adequate and supported judgment.
Was termination in the children's best interests?	The mother asserted her bond and parental abilities weighed against termination.	The state cited ongoing risk, trauma, and lack of a safe environment.	Termination found to be in the best interests of the children.

In re Samantha C., 268 Conn. 614 (Conn. 2004) (addresses burden of proof and grounds for parental termination)
In re Shane M., 318 Conn. 569 (Conn. 2015) (clarifies standard of review for failure to rehabilitate determinations)
In re Melody L., 290 Conn. 131 (Conn. 2009) (details clear and convincing evidence requirement for termination)
In re Ryder M., 211 Conn. App. 793 (Conn. App. Ct. 2022) (reaffirms strict compliance with statutory criteria in termination cases)
In re Nevaeh G.-M., 217 Conn. App. 854 (Conn. App. Ct. 2023) (failure to acknowledge and address partner violence as failure to rehabilitate)
In re Jason R., 306 Conn. 438 (Conn. 2012) (addresses proper allocation of burden of proof in parental termination proceedings)