In re Elijah C., 164 Conn.App. 518

Child born; hospital raised concerns about mother's cognitive limitations and schizophrenia; department obtained ex parte temporary custody and filed a neglect petition based on predictive neglect.
Juvenile court adjudicated the child neglected and committed custody to the Department of Children and Families (the department); ordered the department to explore additional services and report to the court.
The department provided case management, in‑home visits with parenting components, supervised visitation options, transportation to medical visits, and arranged psychological evaluations.
Two psychological evaluations (one pretrial, one departmental) found the mother intellectually disabled with extremely low adaptive functioning and concluded she could not independently parent Elijah and was unlikely to benefit from remediation alone.
Trial court (termination hearing) found by clear and convincing evidence that the department had made reasonable reunification efforts and that the mother was unable to benefit from those efforts; it terminated parental rights.
Appellate court dismissed the mother’s appeal as moot because she challenged only the reasonable‑efforts finding and failed adequately to challenge the alternative, independent finding that she was unable to benefit from reunification services.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether department failed to provide services reasonably accommodating mother's intellectual disabilities	Mother: Services were not tailored to her cognitive limitations; department curtailed services and thus did not reasonably accommodate her disabilities	Petitioner: Mother’s challenge is moot because the trial court made an alternative finding that she could not benefit from services and that finding was not challenged	Appeal dismissed as moot; court declined to review reasonable‑efforts claim because mother did not adequately challenge the independent finding that she could not benefit from services
Whether department violated court order to continue reunification services before filing termination petition	Mother: Department ignored trial court’s earlier order to give her more time and reduced services then filed to terminate rights	Petitioner: Mootness; substantive dispute not reviewable absent challenge to the alternate inability‑to‑benefit finding	Not reached on merits due to mootness dismissal
Whether statute requires additional or specialized services to give intellectually disabled parents a reasonable chance at reunification	Mother: Department must provide services specifically enabling intellectually disabled parents to retain custody	Petitioner: Mootness; record shows services offered and evaluations showed limitations beyond remediation	Not reached on merits; appeal dismissed as moot

State v. Nardini, 187 Conn. 109 (threshold justiciability/mootness test)
In re Jorden R., 293 Conn. 539 (statute permits court to find either reasonable efforts or that parent is unable/unwilling to benefit; failure to challenge both renders appeal moot)
In re Brianna C., 98 Conn. App. 797 (predictive neglect can be based on potential risk)
In re Kachainy C., 67 Conn. App. 401 (briefing requirements for challenging trial findings)
In re Alison M., 127 Conn. App. 197 (appellate courts will not decide moot questions)