In re Riley B., 203 Conn.App. 627

DCF had prior involvement with respondent's family since 2009; in March–June 2018 concerns of physical and emotional abuse led to investigation and criminal charges against the respondent for assault and risk of injury to a child.
The children were removed in July 2018 and placed in foster care after the respondent was arrested; Riley was adjudicated neglected and committed to the Commissioner.
A permanency plan of termination of parental rights and adoption for Riley was approved in June 2019; the petitioner filed a termination petition on August 1, 2019 under § 17a-112(j)(3)(B)(i) (failure to rehabilitate).
A maternal relative in New Jersey contacted DCF in June 2019 offering to be an adoptive resource; an ICPC package was delayed and not submitted until about one week before the December 5, 2019 trial, so ICPC results were pending at trial.
The respondent (incarcerated at trial) moved to transfer guardianship to the out-of-state relative and asked for a stay pending ICPC; the trial court denied the transfer and stay, found statutory grounds and best interests met, and terminated the respondent’s parental rights.
On appeal the respondent argued the termination violated her substantive due process rights because transfer of guardianship to the out-of-state relative was a less restrictive alternative; the court declined to review the unpreserved constitutional claim because the record lacked the basic factual predicate that the relative was amenable to guardianship.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether terminating parental rights violated respondent's substantive due process right because a transfer of guardianship to an out‑of‑state maternal relative (ICPC pending) was a less restrictive alternative	Petitioner: record lacked evidence the relative was willing/amenable; ICPC incomplete; statutory termination criteria were met	Respondent: strict scrutiny required; no compelling reason to sever parental rights while awaiting ICPC because transfer was a less restrictive means to protect child and provide permanency	Court: Affirmed. Declined to review unpreserved constitutional claim under Golding because the record was inadequate—no evidence the relative was amenable to guardianship (Golding prong one failed).

State v. Golding, 213 Conn. 233 (establishes four‑part test for review of unpreserved constitutional claims)
In re Azareon Y., 309 Conn. 626 (record must contain factual predicates to review unpreserved substantive‑due‑process claims)
In re Brayden E.-H., 309 Conn. 642 (court noted unresolved question whether least‑restrictive‑means analysis is required for termination proceedings)
In re Yarisha F., 121 Conn. App. 150 (ICPC completion required before transferring guardianship to out‑of‑state relative)
In re Elijah C., 326 Conn. 480 (explains statutory framework and required findings for termination under § 17a‑112)
State v. Canales, 281 Conn. 572 (reiterates narrow scope of Golding exception)