In re S. D.

Conn. App.

June 16, 2009


In this appeal of a termination of parental rights case, the appellate court found that pursuant to C.G.S. § 17a-112(j), the trial court was not required to make a “reasonable efforts” finding that attempts were made to locate the father and reunite the father with his child. A trial court may determine that the “reasonable efforts” finding is not necessary when “the court finds … that the parent is unable or unwilling to benefit from reunification efforts o … or determines at trial on the petition, that such efforts are not required.” The appellate court noted that the trial court made detailed findings that the father was unwilling to benefit from reunification services in that the father continued to be homeless, lacked legal income, remained involved with the criminal justice system, and had abandoned the child in question. The court held that the “unwilling to benefit” finding was the functional equivalent of a finding that “such efforts are not required,” and said finding was amply supported by the record.

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