In re Kyara H., 83 A.3d 1264

Father (respondent Tyrone H.) had minimal involvement with children Kyara and Jahein and a lengthy criminal history including domestic violence; he was incarcerated when termination petitions were filed and released shortly after.
Children were removed from mother repeatedly for neglect, substance exposure and domestic violence; department obtained temporary custody in October 2011 and termination petitions were filed July 25, 2012.
The respondent repeatedly told DCF he would not participate in services, declined referrals while incarcerated, and did not engage meaningfully with the children during supervised visits or after release.
The trial court found by clear and convincing evidence that (1) children had been previously adjudicated neglected, (2) respondent was provided specific steps, and (3) respondent failed to achieve personal rehabilitation such that he could assume a parental role within a reasonable time.
The sole appellate claim challenged the court’s finding that the Department of Children and Families made reasonable efforts to reunify the respondent with his children, arguing DCF was required to continue efforts through the end of trial and did not contact him after his August 2012 release.
The Appellate Court affirmed, holding the record supported that DCF made reasonable efforts and that continued efforts would have been futile given respondent’s consistent refusal to cooperate.

Issue	Plaintiff's Argument (Commissioner / DCF)	Defendant's Argument (Respondent)	Held
Whether §17a-112(j)(1) required DCF to continue reasonable reunification efforts through the termination trial date	DCF (and commissioner) argued court’s finding need not reflect futile post-filing efforts; reasonable efforts were measured against the circumstances and respondent’s noncooperation	Respondent argued statute requires DCF to keep making reasonable efforts until trial conclusion and DCF did not contact him after his release in Aug 2012	Court affirmed that, on these facts, the finding was supported: DCF’s prior efforts and the respondent’s persistent refusal made further efforts futile; outcome stands (affirmed)
Whether evidence supported finding that DCF made reasonable efforts to reunify respondent with children	DCF pointed to prior offers of services, specific steps given, outreach attempts while incarcerated, and respondent’s explicit rejections and lack of engagement	Respondent argued DCF failed to refer or contact him after release and thus did not satisfy ongoing duty to make reasonable efforts	Court held evidence was sufficient: respondent consistently rebuffed services, did not engage post-release, and one short alcohol program (likely probation-required) was insufficient to show willingness to rehabilitate; reasonable efforts finding not clearly erroneous

In re Roshawn R., 51 Conn. App. 44 (discusses two-phase termination hearing structure)
In re Anthony H., 104 Conn. App. 744 (adjudicatory consideration may include events after petition when assessing rehabilitation)
In re Eden F., 250 Conn. 674 (defines personal rehabilitation standard)
In re Galen F., 54 Conn. App. 590 (importance of respondent's parenting history)
In re Christopher B., 117 Conn. App. 773 (reliance on respondent's history with DCF)
In re Jennifer W., 75 Conn. App. 485 (court must consider full history of parenting abilities)
In re Melody L., 290 Conn. 131 (standard of review for reasonable-efforts finding)
In re Ebony H., 68 Conn. App. 342 (reasonableness means doing everything reasonable, not everything possible)
In re Antony B., 54 Conn. App. 463 (no duty to continue futile efforts when parent refuses services)
In re Christopher C., 134 Conn. App. 473 (department not required to continue efforts when parent refuses to engage)
In re Samantha C., 268 Conn. 614 (abandoning reunification can be reasonable given child’s needs and history)
In re Daniel C., 63 Conn. App. 339 (department may cease reunification efforts after prolonged unsuccessful attempts)
In re Sheena I., 63 Conn. App. 713 (totality of evidence supports termination when reasonable inferences drawn)
State v. Reynolds, 264 Conn. 1 (ambiguous record read to support judgment absent articulation)