In Re Zowie N., 135 Conn. App. 470

The respondent, Jeffrey N., appeals from a trial court judgment terminating his parental rights to his daughter Zowie N.
The underlying removal occurred in April 2008 due to the mother's prenatal substance abuse, domestic violence, and endangerment concerns; services were offered to both parents.
Zowie was adjudicated neglected in August 2009; a petition to terminate the respondent's rights was filed, and the mother consented to termination in April 2010.
In August 2010, the petitioner amended to seek termination of the respondent, alleging lack of rehabilitation, abandonment, and no ongoing parent‑child relationship; the nine‑day hearing ran from September 27, 2010, to March 3, 2011.
The respondent represented himself with standby counsel; the court issued a May 6, 2011 written decision terminating the respondent's parental rights by clear and convincing evidence.
The court found the department had made reasonable efforts to reunify, but the respondent failed to achieve the required rehabilitation, and there was no ongoing meaningful parent‑child relationship; best interests were also determined in the dispositional phase.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a valid waiver of counsel and proper advisement under § 45a-717 (b)?	Jeffrey N. asserts no effective waiver without a thorough canvass.	State argues court properly advised and respondent voluntarily waived counsel.	Yes; court complied with advisement and waiver was valid.
Does due process require a second competency hearing addressing self‑representation when a parent elects to represent themselves?	No second competency evaluation was required.	Respondent contends a second evaluation should address self‑representation competence.	No second competency evaluation required; record supports competence to represent himself.
Did the department's efforts to reunify the child with the respondent constitute reasonable efforts?	Department provided visitation, counseling, and other services; efforts were reasonable.	respondent argues services were insufficient and failed to address relationship with mother.	Yes; department made reasonable efforts, and respondent failed to benefit.
Was there clear and convincing evidence that the respondent failed to achieve the required personal rehabilitation?	respondent did not address mental health, domestic violence, and avoidance of criminal activity as required.	respondent contends steps were ambiguous and rehabilitation was underway.	Yes; evidence supported failure to achieve personal rehabilitation.

In re Samantha C., 268 Conn. 614 (2004) (indigent parental right to counsel required by statute; not constitutionally required)
In re Baby Girl B., 224 Conn. 263 (1992) (waiver standards for termination proceedings)
State v. Oliphant, 47 Conn. App. 271 (1997) (waiver of counsel in criminal context admissible if voluntary and informed)
In re Alexander V., 223 Conn. 557 (1992) (competency hearing may be required in termination cases under certain circumstances)
In re Kaleb H., 131 Conn. App. 829 (2011) (trial court's competency determination given deference; no mandatory second hearing)
In re S.D., 115 Conn. App. 111 (2009) (reasonable deference to trial court findings in termination matters)