In re Wendy G.-R.

The respondent mother appealed from the trial court's judgments rendered for the petitioner, the Commissioner of Children and Families, terminating her parental rights with respect to her minor children. The mother, who had been defaulted for failure to appear at the termination proceedings, claimed, inter alia, that the court violated her right to due process by con- structively depriving her of her right to the effective assistance of coun- sel. Held: The respondent mother's claim that the trial court's constructive deprivation of counsel constituted structural error for which prejudice was presumed and a rule of automatic reversal applied was unavailing, as this court declined to apply such a rule in the context of child protection cases. Even if this court assumed that the trial court constructively deprived the respondent mother of her right to the effective assistance of counsel, the mother failed to show resulting prejudice and, thus, any violation of that right was harmless beyond a reasonable doubt. Even if this court assumed that the trial court violated the respondent mother's due process rights when it denied her counsel's request for a continuance of the hearing on the termination petitions because the mother was not present, any error was harmless. Even if this court assumed that the trial court violated the respondent mother's due process rights by failing to provide her and her counsel with adequate notice of the hearing on the petitions to terminate the mother's parental rights, the mother failed to explain at the hearing on the motion to open the judgments what additional evidence she would have presented had she and her counsel received proper notice and, accordingly, the trial court's error was harmless beyond a reasonable doubt. Argued September 10—officially released November 25, 2024 In accordance with the spirit and intent of General Statutes § 46b-142 (b) and Practice Book § 79a-12, the names of the parties involved in this appeal are not di

The petitioner, the Commissioner of Children and Families, sought to termi- nate the respondents' parental rights with respect to their minor child. Due to the COVID-19 pandemic, the trial on the termination petition was held remotely via Microsoft Teams. The respondent mother was represented by counsel and participated in the proceedings by telephone. The respondent father consented to termination. At the conclusion of the trial, the trial court rendered judgment terminating the respondents' parental rights. On the respondent mother's appeal, held that, pursuant to State v. Golding (213 Conn. 233), the record was inadequate to review the mother's claim that, by requiring her to participate in a virtual trial to terminate her parental rights without providing her with an electronic device that allowed her to appear before the court in the same manner as if she were on trial in a courtroom, she was denied due process of law and equal protection of the law under the fourteenth amendment to the United States constitution: although the parties agreed that the mother participated via telephone outside the proximity of her counsel, the record was silent as to whether the mother chose to turn her video off or whether she was unable to participate via video as a result of inadequate technology; moreover, other than one connectivity issue during the mother's canvass, there was no indication that she had diffi- culty hearing or participating at the trial, and the trial court repeated the canvass after being advised of the connectivity issue; furthermore, the mother did not ask for any technical assistance or accommodation during the trial; accordingly, the situation was analogous to that set forth in In re Vada V. (343 Conn. 730), in that the trial court was unable to assess any potential problems with the mother's ability to participate via video and had no occasion to consider alternative means for her to participate, to provide her with technology or Internet access, or to

The Tennessee Department of Children's Services ("DCS") removed three children from the custody of their parents and placed them with foster parents in March 2012 because one of the children, an infant, was severely malnourished. By July 2012, the children's mother was cooperating with DCS and complying with a permanency plan that set the goal for the children as reunification with their mother or another relative. The mother continued to comply with the permanency plan for the next sixteen months that the children were in foster care. On the day the children were scheduled to begin a trial home visit with the mother, July 31, 2013, the foster parents filed a petition in circuit court seeking to terminate the mother's parental rights and to adopt the children. After the foster parents filed their petition in circuit court, the juvenile court, which had maintained jurisdiction over the dependency and neglect proceeding, ordered DCS to place the children with the mother for the trial home visit. The circuit court trial on the foster parents' petition did not occur until September 2015. By that time, the children had resided with the mother on a trial basis for two years without incident. The mother, DCS, and the guardian ad litem appointed by the juvenile court in the dependency and neglect proceeding opposed the foster parents' petition. The foster parents and a guardian ad litem appointed by the circuit court sought termination of the mother's parental rights. After the multi-day trial, the trial court dismissed the petition, finding that the foster parents had proven a ground for termination by clear and convincing proof but had failed to establish by clear and convincing proof that termination is in the children's best interests. The foster parents appealed, and the Court of Appeals reversed. We granted the mother's application for permission to appeal and now reverse the judgment of the Court of Appeals and reinstate the trial court's judgment dismissing the fost

In this parental termination case, maternal Grandparents sought termination of both Mother's and Father's rights on the grounds of: (1) abandonment by willful failure to support and (2) abandonment by willful failure to visit. The trial court found no grounds for termination as to Mother and only one ground—failure to support—as to Father. The trial court however found that it was not in the child's best interest to terminate Father's rights. We affirm the trial court's judgment in all respects.