Termination of Parental Rights, Emotional Ties, Permanency Planning
Mother appealed from the judgments terminating her parental rights as to her three minor children. She claimed that the court improperly found that it was in the best interests of the children to terminate her parental rights.
The Appellate Court here held that there was ample evidence to support the trial court’s conclusion that TPR was in the best interests of the minor children, as the court’s findings, made pursuant to statute (§ 17a-112(k)), were factually supported and legally sound, such that it would not substitute its judgment for that of the trial court. Specifically, it found that it was not inappropriate for the court to have considered the bond between the children and their foster parents, as to the emotional ties factor in § 17a-112(k)(4). Although the trial court did not specifically discuss the feelings and emotional ties of the children with respect to Mother when stating its findings, the Court here found that it did not mean that the court failed to consider those feelings and ties: reading the court’s decision as a whole revealed that it had considered them, and determined that the children and Mother did not have a strong bond.
Moreover, when the trial court’s decision was read as a whole, its factual findings supported its conclusion under § 17a-112(k)(3), that Mother had not complied with her visitation obligations in connection with the court’s orders. Furthermore, as to one of the children, Mother did not direct the Court here to any case law indicating that a trial court has an obligation, sua sponte, to consider a less onerous means of achieving permanency planning, in the absence of a motion specifically seeking an alternative permanency plan. Because the issue of whether a transfer of guardianship was appropriate was never raised in the trial court, it made no findings regarding whether such a transfer was in that child’s best interest and a more appropriate disposition than the one approved by the court.