In re Julianna B., 141 Conn. App. 163

On Oct. 6, 2009, at age 20 months, child was removed from mother and placed with the state under a 96-hour hold after a traumatic incident involving the child's mother.
On Oct. 16, 2009, the children were adjudicated neglected and committed to the Department of Children and Families (DCF) with specific steps directed at the respondent.
The sisters have remained in foster care since Dec. 26, 2009.
On Oct. 15, 2010, DCF petitioned to terminate the respondent's parental rights based on a lack of personal rehabilitation.
On July 19, 2012, the trial court terminated the respondent's parental rights after finding a statutory ground and that termination was in the child's best interests.
The respondent completed services and had periods of stability but the court found insufficient rehabilitation; placement options with relatives were considered but ruled out; the record did not include evidence on alternatives like transfer of guardianship to paternal aunt or open adoption by the foster mother; the trial court did not make specific findings on these alternatives; the respondent did not preserve the claim at trial and relies on Golding for appellate review; the appellate court held the record inadequate to review the claim and affirmed the termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record is adequate to review a substantive due process challenge.	respondent argues record lacks basis for least restrictive means analysis.	petitioner contends record supports termination; no need for remand.	Record inadequate for review; affirmed.
Whether strict scrutiny or least restrictive means applies to § 17a-112 termination.	respondent contends strict scrutiny/least restrictive approach required.	court found no applicable strict scrutiny requirement for this statute.	Holding that Santosky procedural standard not applicable here; record inadequate to review under Golding.
Whether the court erred by not evaluating less restrictive alternatives (e.g., guardianship transfer to paternal aunt or open adoption).	respondent argues these alternatives could have avoided termination.	petitioner did not litigate or find sufficient facts on these alternatives.	Record inadequate to review; unpreserved claim fails under Golding.
Whether Golding’s first prong was satisfied to address unpreserved constitutional error.	respondent asserts adequate record for Golding review.	record insufficient to review; cannot reach constitutional merits.	Golding prong satisfied? record inadequate; claim fails.

In re Azareon Y., 60 A.3d 457 (Conn. App. 2012) (record inadequate; presumption against extending review to unpreserved claims)
In re Brendan C., 874 A.2d 826 (Conn. App. 2005) (Golding analysis and preservation considerations in termination cases)
In re Michael L., 745 A.2d 847 (Conn. App. 2000) (adjudication and dispositional phases; statutory criteria must be strictly complied)
Santosky v. Kramer, 455 U.S. 745 (1982) (procedural due process; not controlling where record not litigated at trial)
Roth v. Weston, 259 Conn. 202 (2002) (recognition of parental fundamental liberty interest; context for scrutiny discussion)