In re Jason M., 140 Conn. App. 708

Petitioner, commissioner of children and families, sought terminated parental rights for Charline P. as to Jason, Rosalinda, Hudsana and Richardson.
Children were adjudicated neglected and committed to department custody between 2009 and 2010; Richardson initially placed under protective supervision after birth.
A reunification plan was approved in 2011 with Jason to be reunified first; Rosado, the psychologist, cautioned about further reunifications after Jason’s deterioration.
Trial on termination occurred April 16, 2012; the court found reasonable reunification efforts and that Charline failed to achieve sufficient rehabilitation.
Court concluded no ongoing parent-child relationship with the four children and that termination was in their best interests; orders of termination entered.
Charline appealed raising notice/confrontation, factual findings, burden-shifting, and various post-judgment motions; multiple issues decided in petitioner’s favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process and confrontation notice	Petitioner asserts proper notice and defendant waived confrontation by absence.	Charline contends lack of notice and Confrontation rights violation due to absence.	Notice adequate; confrontation rights waived by deliberate absence.
Reasonable efforts to reunify	Department offered extensive services and demonstrated efforts to reunify.	Charline claims efforts were insufficient or improperly evaluated.	Court properly found reasonable efforts to reunify were made.
Personal rehabilitation	Charline failed to achieve the degree of personal rehabilitation required.	Charline argues rehabilitation was sufficient or ongoing progress was achieved.	Court correctly concluded lack of sufficient rehabilitation for all four children.
Best interests/disposition	Termination in minors’ best interests supported by seven statutory factors and evidence.	Charline disputes best-interest findings and ignores potential for future rehabilitation.	Termination in children's best interests affirmed; no error in disposition.
Burden of proof on rehabilitation	Court properly applied burden on petitioner to prove statutory grounds and rehabilitation.	Charline contends court improperly shifted burden to her.	No improper burden shifting; petitioner met clear and convincing standard.

In re Destiny R., 134 Conn. App. 625 (Conn. App. 2012) (standard for appellate review of termination findings)
In re Melody L., 290 Conn. 131 (Conn. 2009) (reunification and rehabilitation standards)
In re Jason R., 129 Conn. App. 746 (Conn. App. 2011) (reasonable efforts/rehabilitation framework)
State v. Lopez, 235 Conn. 487 (Conn. 1996) (due process and notice principles in jeopardy proceedings)
In re Brianna L., 139 Conn. App. 239 (Conn. App. 2012) (adequacy of appellate briefing and issues preservation)