In re Alexander T.

Connecticut Appellate Court

81 Conn. App. 668 (2004)

February 24, 2004


The Connecticut Appellate Court affirmed a trial court’s judgment terminating a mother’s parental rights with respect to her two sons, Alexander T. and Elijah T. Although affirming the lower decision, the appellate court addressed each of the three arguments put forth by the respondent.

The court first addressed the mother’s argument that the lower court incorrectly ruled that the Department of Children and Families (“DCF”) made reasonable efforts to reunify the mother with her two sons under Conn. Gen. Stat § 17a-112. The appellate court admitted that its standard of review was limited to reviewing whether the trial court’s decision was “clearly erroneous.” The court then explained that DCF’s actions (including attempts to refer the mother to drug rehabilitation programs and counseling) satisfied the requirement to make reasonable efforts to reunify the mother with her children.

The court then addressed the argument that the lower court incorrectly decided that the mother was unable/unwilling to benefit from DCF’s efforts at reunification. The court responded that the trial court’s reference to the mother’s “track record” of failing to take advantage of DCF’s attempts at reunification was sufficient evidence to show her unwillingness to benefit from DCF’s reasonable efforts at reunification.

Finally, the court addressed the argument that the evidence was insufficient to show that the mother failed to achieve sufficient personal rehabilitation. The court explained that lower court had sufficient evidence of the mother’s history (including expert and lay witnesses) before deciding that the respondent had failed to achieve personal rehabilitation so that termination of her parental rights was necessary under § 17a-112 (j)(3)(B)(ii).

In an interesting side note, Judge Dupont commended “Counsel for the . . . respondent . . . for their excellent briefs and oral arguments.” She further noted that: “Counsel for the respondent were certified legal interns from University of Connecticut School of Law legal clinic.” See footnote 2 at 669.

The decision may be accessed by going to the state Judicial Branch website at

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