226 Conn.App. 651
Conn. App. Ct.2024Background
- The respondent father appealed the trial court's decision terminating his parental rights to his two minor children, J and A, after they were adjudicated neglected and removed from parental care.
- The trial court found, by clear and convincing evidence, that the statutory grounds for termination under Conn. Gen. Stat. § 17a-112(j) were met, including failure to rehabilitate and lack of ongoing parent-child relationship.
- The father had a history of failing to comply with reunification steps, including refusing substance abuse and domestic violence treatment, and declining visitation while incarcerated.
- The children had therapeutic needs due to exposure to trauma, and the respondent failed to support or participate in relevant interventions for himself or the children.
- Both children were bonded with their foster parents and had not had significant contact or bond with the respondent, particularly J, whom the respondent had not seen since 2019.
- The attorney for the minor children supported the decision to terminate parental rights, and the respondent mother's rights were terminated by consent and not at issue on appeal.
Issues
| Issue | Respondent's Argument | Petitioner's Argument | Held |
|---|---|---|---|
| Whether termination was in the children's best interests | He had an existing bond and relationship with the children | Lack of bond, failure to address children's needs, ongoing parental deficiencies | Trial court not clearly erroneous; termination proper |
| Sufficiency of evidence supporting termination | Affection and prior contact show continued connection | Abundant evidence of deficiencies, lack of improvement, no bond | Sufficient evidence supported court's conclusion |
| Consideration of less restrictive alternatives | Court should have considered guardianship with relatives | Not raised or briefed; inadequate to review | Claim not reviewed due to inadequate briefing |
| Compliance with reunification efforts | He declined visits to protect kids from prison environment | Father declined all visits post-incarceration without valid record reason | No error in court's finding on lack of effort |
Key Cases Cited
- In re Davonta V., 285 Conn. 483 (standard for reviewing trial court termination decision)
- In re Brayden E.-H., 309 Conn. 642 (deference to trial court in termination proceedings)
- In re Alison M., 127 Conn. App. 197 (dispositional phase and best interest analysis)
- In re Malachi E., 188 Conn. App. 426 (balancing findings in best interest analysis)
- In re Ryder M., 211 Conn. App. 793 (parental affection not determinative for best interests)