In Re Luciano B., 129 Conn. App. 449

Luciano, born April 2008, tested positive for cocaine at birth and was placed in DCF custody shortly after birth.
May 16, 2008, the commissioner filed a petition for neglect and sought temporary custody due to parental substance abuse and domestic violence issues.
July 17, 2008, Luciano was adjudicated neglected and committed to the commissioner; reunification steps were ordered for both parents addressing depression, substance abuse, and domestic violence.
The father had a lengthy criminal history including domestic violence; the mother had long-standing substance abuse issues and a history of unstable housing.
Both parents participated inconsistently in services; the father was incarcerated in 2008–2009, delaying his participation in treatment programs, and the mother repeatedly missed or terminated treatment.
By May 2009, the petition for termination of parental rights was filed; by September 2009, psychologist Randall recommended three additional months for strict treatment compliance, which the court noted in rescheduled proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the department made reasonable efforts to reunify the father	Father: department failed to monitor and tailor services; visitation was too limited.	Father: department should have increased contact and adjusted plan; failed to engage while incarcerated.	No error; department reasonably pursued reunification efforts.
Whether the department made reasonable efforts to reunify the mother	Mother: department failed to engage despite multiple referrals and some progress.	Mother: department repeatedly referred her to appropriate treatment and she showed efforts.	No error; department reasonably pursued reunification efforts.
Whether the parents failed to achieve personal rehabilitation	Both parents failed to demonstrate sufficient rehabilitation within a reasonable time given Luciano's age.	Father and mother argue progress and potential for future rehabilitation.	Yes; both failed to achieve sufficient rehabilitation.
Whether termination was in Luciano's best interests	Continued parental rights were not in Luciano's best interests due to instability and lack of permanency.	Parents contend progress and bond with Luciano justify continued parental rights.	Yes; termination was in Luciano's best interests.

In re G.S., 117 Conn. App. 710 (2009) (reasonable efforts mean doing everything reasonable, not everything possible)
In re Vincent B., 73 Conn. App. 637 (2002) (no efforts at reunification at all warranted termination)
In re Latifa K., 67 Conn. App. 742 (2002) (post-filing rehabilitation considerations allowed)
In re Sole S., 119 Conn. App. 187 (2010) (appellate deference to trial court on rehabilitation findings)
In re Tremaine C., 117 Conn. App. 590 (2009) (needs of the child guide rehabilitation assessment)
In re Jennifer W., 75 Conn. App. 485 (2003) (consideration of full history alongside progress)
In re Davonta V., 285 Conn. 483 (2008) (best interests deference to trial court)
In re Shyliesh H., 56 Conn. App. 167 (1999) (stability and permanency required for permanency planning)