In re Natalie S., 160 A.3d 1056

Background

Natalie, a minor, was adjudicated neglected after the Department of Children and Families (DCF) removed her from her mother, Heather S.
The biological father, Matthew B., initially noncustodial and unknown to him because the mother concealed Natalie’s whereabouts, later appeared and was adjudicated father by paternity testing.
The trial court found the mother unsuitable and the father suitable; it vacated DCF custody and granted temporary (nonpermanent) custody and legal guardianship to the father, without ordering continued DCF supervision.
DCF had provided reunification services to the mother through the neglect hearing and had no identified service needs for the father.
The mother appealed, arguing DCF was required by statute to continue reunification efforts for her; the Appellate Court and this Supreme Court affirmed that DCF was not required to continue reunification once guardianship/custody was placed with the father.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 17a-111b requires DCF to continue reunification efforts for the mother after the court awarded custody/guardianship to the father	The statute’s plain language mandates DCF make reasonable efforts to reunify a parent with a child unless exceptions apply; neither exception applied, so efforts must continue for the mother	Statutory text and related provisions allow reunification efforts to be satisfied by reunification with one parent; vesting guardianship/custody in a third party (the father) ends DCF’s reunification obligation	The court held DCF need not continue reunification efforts for the mother once custody/guardianship was placed with the father; reunification with one parent satisfies § 17a-111b
Whether the mother’s retained parental rights and constitutional family integrity require continued DCF reunification efforts despite transfer of custody/guardianship	Mother argued she retains a fundamental right to family integrity and DCF must protect it by continuing reunification efforts	State argued child’s best interest and the father’s family integrity (as guardian/custodian) outweigh continuation of state reunification efforts for the mother; the statutory scheme contemplates cessation of DCF involvement when guardianship is vested in a third party	Court rejected mother’s constitutional argument; once guardianship/custody vested in the father, continued state reunification efforts would conflict with the father’s and child’s family integrity and were not required

Key Cases Cited

Cales v. Office of Victim Services, 319 Conn. 697 (statutory construction; plenary review)
McCullough v. Swan Engraving, Inc., 320 Conn. 299 (interpretation of singular vs. plural legislative wording)
State v. Agron, 323 Conn. 629 (harmonious statutory construction principle)
In re Allison G., 276 Conn. 146 (goals of neglect proceedings: child safety and permanency; role of specific steps)
Fish v. Fish, 285 Conn. 24 (periodic judicial review applies only when child is committed to DCF custody)
In re Pedro J. C., 154 Conn. App. 517 (transfer of guardianship to nonparent ends requirement that reunification efforts be made)
In re Leah S., 284 Conn. 685 (recognition of parental right to raise children and role of reunification efforts)