December 1, 2020

In Re Miracle C. (AC 44006)

TPR, Reasonable Efforts

Takeaway: In order to challenge a court’s finding of reasonable efforts, a parent must challenge all of the court’s findings relating to such.

Mother appealed from the judgment terminating her parental rights, claiming that the court erroneously concluded that DCF had made reasonable efforts at reunification because although their plan was to engage her in dialectical behavioral therapy, it failed to inform her that she should have engaged in that therapy. The trial court also found that Mother was unable or unwilling to benefit from reunification efforts.

The Appellate Court held that because Mother, who did not challenge the trial court’s finding that she was unable or unwilling to benefit from reunification efforts, and instead only challenged one of the two separate and independent bases for the court’s determination that the reasonable efforts requirements had been satisfied, there therefore existed a separate and independent basis for upholding the court’s determination, and, as such, there was no practical relief that could be afforded to her.  Accordingly, the appeal was dismissed as moot.