April 6, 2023

April 2023

Mother appealed the termination of her parental rights, claiming that the trial court erroneously concluded that DCF had made reasonable efforts at reunification pursuant to statute (§ 17a-112 (j) (1)).

The Appeals Court held that, because Mother challenged only 1 of the 2 separate bases for upholding the trial court’s determination that the reasonable efforts requirements had been satisfied, her appeal was moot because there was no practical relief that the Court could provide.  Although the trial court found both that DCF made reasonable efforts to reunify and that Mother was unable or unwilling to benefit from reunification efforts, in her principal appellate brief, Mother challenged only the reasonable efforts finding.  Moreover, although Mother’s statement of issues and a heading in her brief referenced the court’s finding that she was unable or unwilling to benefit from reunification efforts, the argument section of her brief did not provide legal analysis on this point.

https://www.jud.ct.gov/external/supapp/Cases/AROap/AP218/218AP138.pdf
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