In re Noah R.-R., AC48482

The Commissioner of Children and Families petitioned to terminate the parental rights of both parents to the minor child, Noah R.-R.; the petition against the mother was withdrawn before trial.
The Department of Children and Families made reasonable efforts to locate and reunify the father, Jorge R.-M., with Noah, but these efforts were unsuccessful.
The court found that the father was unwilling or unable to benefit from reunification efforts, and that Noah had previously been adjudicated neglected.
The father failed to achieve sufficient personal rehabilitation, despite being provided with specific steps to enable reunification, such that the court could not believe he would be ready to assume responsibility for Noah within a reasonable time.
The court also found that Noah had been denied necessary care as a result of acts or omissions by the father, including a pattern of abuse.
The trial court concluded, considering statutory factors, that termination of the father’s rights was in Noah’s best interest, and the appellate court affirmed this judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether terminating the father's parental rights was in the best interest of the child	Court properly determined best interest	Court improperly determined best interest; asserts continued parental rights better serve the child	Termination was in the child’s best interest; affirmed
Sufficiency of efforts for reunification and benefit from services	All statutory requirements for reunification and rehabilitation attempts met	Asserted errors in determining father's ability to benefit from reunification	Court found father failed to rehabilitate; statutory requirements satisfied
Legality and reasonableness of the factual findings	Factual findings are thorough, well-reasoned, and supported by record	Contested sufficiency and accuracy of findings, especially in dispositional phase	Factual findings supported; adopted in full by appellate court
Constitutional or lesser restrictive means arguments	Not raised or briefed by State	Reference made but not pressed or properly briefed by father	Not adjudicated; not properly before court

In re Karrlo K., 40 Conn. App. 73 (1996) (upheld termination of parental rights when the trial court’s comprehensive decision is supported by the record)
Kennynick, LLC v. Standard Petroleum Co., 222 Conn. App. 234 (2023) (affirmed adoption of well-reasoned trial court memoranda by appellate court)
Trejo v. Yale New Haven Hospital, Inc., 218 Conn. App. 781 (2023) (addressed standards for appellate review of well-articulated trial court decisions)