Synopses of cases recently decided in Connecticut's
state and federal courts and the U.S. Supreme Court regarding Abuse
and Neglect, Adoption, Civil Liberties, Discrimination, Education,
Family Law, Guardianship, Juvenile Justice, Legal Representation,
Medicaid, and Mental Health.
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In
re Kaleb H. (October, 2011)
Connecticut Appellate Court
October 25, 2011
Competency
Examination
The question in this
appeal is whether the trial court abused its discretion in denying
the respondent mother's request for a competency examination
at a motion to revoke the child's commitment to the Commissioner
of the Department of Children and Families ("Department"). The
court upheld the trial court's decision to deny the request
primarily based on the conclusion that the respondent mother
did not raise specific factual allegations sufficient to raise
a reasonable doubt as to her competence - and that the court,
though observation and assessment during the proceedings, was
in the best position to assess whether she (respondent mother)
behaved rationally at that time.
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In
re Emoni W. (June, 2011)
Connecticut Appellate Court
June, 2011
Application
of Interstate Compact on the Placement of Children to Nonresident
Parents
On
July 9, 2010, the children were removed from their mother’s
home after she was arrested for various drug charges with intent
to sell and for four counts of risk of injury to a child. On
July 12, 2010, DCF sought an order of temporary custody. DCF
then learned about the children’s father (respondent appellant),
who was living in Pennsylvania and had been responsible for
the children’s care for extended periods of time. Father now
wanted the children to come live with him in Pennsylvania.
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In
re Jason R. (June, 2011)
Connecticut Appellate Court
June, 2011
Did
the Court Shift the Burden of Proof to the Respondent? Split
Decision
In
2007, DCF sought, and was denied, temporary custody of Jason
R. and Fernando R. In January, 2008, believing that the children
were in imminent risk of physical harm, DCF removed the children
from the home; they have been in DCF's custody ever since. In
April of that year, the mother pled no contest and court adjudicated
the children neglected and committed them to DCF. The children
are currently in a pre-adoptive placement.
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In
re Joseph W. (June, 2011)
Connecticut Supreme Court
June, 2011
Right
of Noncustodial Parent to Challenge Neglect Petition
The
Connecticut Supreme Court held that a noncustodial parent is
entitled to enter a plea as to whether a child is neglected.
In so holding, the Court affirmed, on different grounds, an
appellate court decision reversing a trial court’s termination
of parental rights.
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In
re Sarah O. (April 26, 2011)
Connecticut Appellate Court
April 26, 2011
Termination
of Parental Rights/Post Trial Evidence/Golding/Reasonable Efforts/Failure
to Rehabilitate
In
this termination appeal, the respondent mother challenged 1)
the trial court’s finding that she failed to rehabilitate; 2)
that DCF made reasonable efforts to reunify her with her daughter;
3) that TPR was in her daughter’s best interests. The respondent
also challenged the court’s reliance on a post trial position
statement from the child’s attorney which contained new information
regarding the child’s post-trial situation. The last claim was
submitted for Golding or “plain error” review as there was no
objection to the statement during post trial proceedings.
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In
re Anvahnay S. (April 19, 2011)
Connecticut Appellate Court
April 19, 2011
Termination
of Parental Rights/Incarcerated Parent
The
appellate court in this case rejected the respondent father’s
contention that the trial court erroneously found that DCF had
made reasonable efforts to reunify him with his daughter, despite
the fact that for much of the duration of the child protection
case, the Department had no contact with the father. Additionally,
the court held that there was sufficient evidence that the father
could not rehabilitate within a reasonable period of time considering
the age and needs of his child.
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In
re Joshua S. (April 5, 2011)
Connecticut Appellate Court
April 5, 2011
Foster
Care Parents/Motion to Intervene/Standing to Appeal
In this appeal of trial
court’s decision to transfer guardianship of baby to his great
aunt in Florida, the Appellate Court held that foster parents
did not have standing to appeal because their motion to intervene
was denied by the trial court and they were not permitted intervention
as a matter of right.
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In
re Johnson R. (April 5, 2011)
Connecticut Supreme Court
April 5, 2011
Due
Process/Incompetent Father
Respondent father had
been found incompetent during the initial phases of the child
protection case and a guardian ad litem had been appointed.
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In
re Lukas K. (April 5, 2011)
Connecticut Supreme Court
April 5, 2011
Due
Process/Rights of Incarcerated parents
In this recent termination
of parental rights appeal, the respondent father, incarcerated
out of state, claimed that the trial court violated his due
process rights by denying his request for a continuance and
release of trial transcripts.
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In
re Mia M. (March 15, 2011)
Connecticut Appellate Court
March 15, 2011
Termination
of Parental Rights/Failure to Rehabilitate
The appellate court
affirmed the trial court's decision to terminate the parental
rights of the respondent mother.
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In
re Alison M. (March 8, 2011)
Connecticut Appellate Court
March 8, 2011
Termination
of Parental Rights/Golding Review/Adequacy of record/procedural
due process/scope of intervenor's role
In this termination appeal, the appellate upheld the trial court's
decision to terminate the respondent's parental rights.
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In
re Chronesca D. (February 8, 2011)
Connecticut Appellate Court
February 8, 2011
Temporary
Custody/Standard
The appellate court reversed the trial court's judgment vesting
temporary custody of the child with a third party where the
court explicitly found that the child was not in immediate danger
from her surroundings.
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In
re Dylan C. January 11, 2011)
Connecticut Appellate Court
January 11, 2011
TPR/Failure
to Rehabilitate/Effective Assistance of Counsel
This termination of parental rights appeal underscores the court’s
emphasis on parental as opposed to personal rehabilitation under
CGS 17a-112(j), as well as the distinction that the court makes
between compliance with specific steps and progress derived
from that compliance.
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In
re Jose B. / In re Jessica M. (December 21, 2010)
Connecticut Appellate Court
December 21, 2010
Jurisdiction
of Court to Adjudicate Youth Neglected Post 18
In these related (but unconsolidated) cases, the Appellate court
upheld the juvenile court’s decision to dismiss the youths’
neglect petitions on the ground that the juvenile court lacked
jurisdiction to adjudicate the petitions once the youths turned
age 18.
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In
re Chevol G. (December 21, 2010)
Connecticut Appellate Court
December 21, 2010
Termination
of Parental Rights/Failure to Rehabilitate
In this per curiam opinion, the appellate court affirmed the
trial court’s termination of parental rights decision, holding
that there was ample evidence in the record to support the findings
that the respondent mother had failed to rehabilitate and that
termination of parental rights was in the children’s best interests.
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In
re Paul O. (December 21, 2010)
Connecticut Appellate Court
December 21, 2010
Order
of Temporary Custody/Adequacy of Evidence
In this appeal of a trial court’s order sustaining an ex-parte
grant of temporary custody to DCF, the respondent mother challenged
the sufficiency of the evidence underlying the trial court’s
finding.
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In
re Brian W. (November 2, 2010)
Connecticut Appellate Court
November 2, 2010
Per
Curium/Guardianship Reinstatement
Pro se father and grandparents appealed trial court’s decision
to reinstate guardianship rights of mother.
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In
re Katia M. (October 26, 2010)
Connecticut Appellate Court
October 26, 2010
Termination
of Parental Rights/Incarcerated Parent
The respondent father claimed that the trial court erreoneously
found that he was “unwilling or unable to benefit from reunification
services” due solely to the father’s status as an incarcerated
individual. The appellate court agreed that while incarceration
alone could not result in a decision to terminate parental rights,
“incarceration nonetheless may prove an obstacle to reunification
due to the parent’s unavailability.”
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In
re Devon W. (October 26, 2010)
Connecticut Appellate Court
October 26, 2010
Termination
of Parental Rights/Failure to Rehabilitate
In this termination of parental rights appeal, the appellate
court affirmed the trial court’s finding that the mother failed
to rehabilitate, despite the mother’s demonstration of continued
progress with mental health treatment.
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In
re Jocquyce. (October 26, 2010)
Connecticut Appellate Court
October 26, 2010
Termination
of Parental Rights/Failure to Rehabilitate
This appeal highlights the distinction trial courts make between
personal and “parental” rehabilitation.
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In
re Albert M. (October 19, 2010)
Connecticut Appellate Court
October 19, 2010
Termination
of Parental Rights/Respondent Father
In this per curiam decision, the appellate court rejected the
respondent father’s argument that the Department failed to meet
its evidentiary burden of proof because it failed to adequately
inform him that separation from the respondent mother would
be necessary in order to reunify him with his child.
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In
re Summer S. (October 19, 2010)
Connecticut Appellate Court
October 19, 2010
Termination
of Parental Rights/Respondent Father
In this per curiam decision, the appellate court, in affirming
the trial court’s termination order, reiterates its observation
regarding the “sad distinction between willingness and ability
parent a child.”
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Juan
F. (September 22, 2010)
Federal Court
September 22, 2010
Court Denies DCF Motion to Vacate Consent
Decree
A federal court ruled that DCF may not be excused from the obligations
of the Juan F. consent decree, a two decade old settlement that
compels DCF to comply with a number of child welfare expectations
on behalf of abused and neglected children.
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In
re A.R. (August 17, 2010)
Connecticut Supreme Court
August 17, 2010
Transfer
of Guardianship/Termination of Parental Rights
In this case involving a pending termination of parental rights
petition and a subsequent intervening grandmother's motion to
transfer guardianship, the Appellate Court held that the trial
court erred in dismissing, sua sponte, the intervenor's motion
to transfer guardianship.
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In
re Shanaira C. (August 10, 2010)
Connecticut Supreme Court
August 10, 2010
Standing Right to Evidentiary Hearing
The Supreme Court determined in this case that the intervener-appellant,
the biological father’s girlfriend, had standing to participate
in a contested motion to revoke commitment/transfer of guardianship
hearing, notwithstanding the trial court’s previous denial of
the intervener’s motions for visitation and custody. The Court
also held that parties have a statutory right to an evidentiary
hearing on any contested motion to revoke commitment.
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In
re Zamora S. (August 3, 2010)
Connecticut Appellate Court
August 3, 2010
Neglect/Termination
of Parental Rights
In
this appeal of a consolidated neglect and termination of parental
rights trial, the Appellate Court held that the trial court
erroneously found that the father neglected a particular child
but that the respondent mother did not.
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In
re Matthew F. (August 3, 2010)
Connecticut Supreme Court
August 3, 2010
Jurisdiction of Juvenile Court/Authority to Issue Post-Majority
Orders
The Supreme Court of Connecticut addressed two discrete topics
in this case: (1) whether the Juvenile Court has jurisdiction
over youths who have turned eighteen, and (2) whether § 17a-11
or § 46b-129 provide statutory jurisdiction for youths eighteen
and older to bring cases in front of the Juvenile Court.
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In
re Kamari C. (July 27, 2010)
Connecticut Appellate Court
July 27, 2010
Neglect/Insufficient
Evidence/OTC
Respondent
mother appealed trial court’s determination that her children
were neglected and should be committed to the Department. The
mother contended that there was insufficient evidence to support
a finding of neglect and that the trial court improperly applied
the doctrine of predictive neglect in adjudicating her children.
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In
re Jan Carlos D (June 15, 2010)
Connecticut Supreme Court
June 15, 2010
Juvenile Justice
The Connecticut Supreme Court addressed the issue as to whether
General Statutes § 54-1f (a) applies to juveniles who are served
with a summons that alleges the commission of criminal offenses.
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In
re Taylor F. (June 8, 2010)
Connecticut Supreme Court
June 8, 2010
Admission
of Children's Statement
The Supreme Court of Connecticut held that children’s out-of-court
statements were admissible under the residual exception to hearsay
rule because the information contained therein was “reasonably
necessary.”
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In
re Joseph W. (June 8, 2010)
Connecticut Appellate Court
June 8, 2010
Determining
Custodial Status of Biological Parent
The Appellate Court of Connecticut reversed a termination
of parental rights decision on the ground that the trial court
erroneously found that the respondent father was the non-custodial
parent of his newborn son.
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In
re Jazmyn B. (May 25, 2010)
Connecticut Appellate Court
May 25, 2010
Appeal:
Termination of Parental Rights
In this novel appeal of a termination of parental rights
decision, the appellate court rejected the respondent father’s
claim that the trial court erroneously found that he had failed
to achieve a sufficient degree of personal rehabilitation and
that C.G.S. § 17a-112 (j) (3) (B) was unconstitutionally vague.
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In
re Jorden R. (May 23, 2010)
Connecticut Appellate Court
May 23, 2010
Remand:
Termination of Parental Rights, Best Interests
On remand from the Supreme Court, the appellate court upheld
the trial court’s finding that it was in the best interest of
the child for the mother’s parental rights to be terminated.
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In
re Jaiden S. (May 4, 2010)
Connecticut Appellate Court
May 4, 2010
Termination
of Parental Rights, Failure to Rehabililitate
In this termination of parental rights case, the appellate
court rejected the respondent father’s claim that DCF failed
to make reasonable efforts to reunify him with his child and
that there was insufficient evidence to find that he failed
to rehabilitate as a parent.
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In
re Yarisha F (May 11, 2010)
Connecticut Appellate Court
May 11, 2010
Transfer
of Guardianship/Interstate Compact
Interpretation of the Interstate Compact on the Placement of
Children is the central issue in this transfer of guardianship
appeal.
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In
re Marcus S. (April 27, 2010)
Connecticut Appellate Court
April 27, 2010
TRANSFER
OF GUARDIANSHIP. MOTION FOR CONTEMPT. In this transfer of
guardianship case, the appellate court affirmed the trial court’s
denial of the father’s motion to hold the Department in contempt
for failing to make service referrals and for failing to develop
a permanency plan that supported reunification.
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In
re Jaime S. (April 27, 2010)
Connecticut Appellate Court
April 27, 2010
Termination
of Parental Rights/Abandonment/Incarcerated Father
In this appeal, the respondent father challenged the trial court’s
decision to terminate his parental rights on the grounds of
abandonment.
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In
re Lukas K. (April 20, 2010)
Connecticut Appellate Court
April 20, 2010
Termination
of Parental Rights: Due Process, Rights of Incarcerated
Father
The appellate court denied the incarcerated father’s claim that
his due process rights were violated when the court failed to
grant his motion for transcripts and a continuance of the termination
of parental rights trial.
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In
re Ellis V. (April 20, 2010)
Connecticut Appellate Court
April 20, 2010
Termination
of Parental Rights: Failure to Rehabilitate.
Evidence
In
this termination of parental rights case, the appellate court
denied the respondent parents’ claim that the trial court erroneously
terminated their parental rights on “failure to rehabilitate”
grounds, and that the trial court improperly admitted the DCF
social study as a “business record.”
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In
re Kelsey M. (April 20, 2010)
Connecticut Appellate Court
April 20, 2010
Order
of Temporary Custody
In
this appeal of an Order of Temporary Custody decision, the appellate
court affirmed the trial court’s determination that the children
were in imminent risk of harm as a result of their mother’s
history of untreated mental health problems, her recent threats
to hurt herself and others while in the presence of her children,
and her and her spouse’s denial of the gravity of these developments.
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CCJEF
v. Rell (March 10, 2010)
295
Conn. 240 (2010)
Education
This case was brought on behalf of individual plaintiffs'
children who attend public schools in Bridgeport, Danbury, Windham,
Hartford, New Haven, East Hartford, New London, Plainfield,
and New Britain.
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In
re Jordan T (March 9, 2010)
Connecticut Appellate Court
March 9, 2010
Termination
of Parental Rights: Incarceration, Best Interests, Post-Adoption
Contact
This
termination of parental rights appeal raises important questions
regarding the impact of parental incarceration on a court's
finding that a parent has not or cannot rehabilitate, and the
legal significance that post-adoption contact with a child's
biological family should have on the court's "best interests"
finding.
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In
re Christopher G (December 22, 2009)
Connecticut Appellate Court
December 22, 2009
Termination
of Parental Rights/Consent/Open Adoption
The
main issue in this appeal was the trial court's denial of the
mother's motion to open a judgment of voluntary termination
of her parental rights. The mother contended that judgment should
have been vacated because the mother's consent was contingent
on the child being adopted by relative foster parents and the
open adoption agreement between the relatives and the mother,
and the child was ultimately adopted by another couple after
the termination proceeding concluded.
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In
re Kaitlyn A (November 3, 2009)
Connecticut Appellate Court
November 10, 2009
Unsuccessful
Appeal of a Termination of Parental Rights:...In
this unsuccessful appeal of a termination of parental rights,
the respondent mother raised two issues. First - she claimed
that the trial court erred by not allowing her a continuance
for the appointment of new counsel despite her inability to
communicate with her existing counsel. Second - she claimed
that the court improperly found that she failed to achieve a
sufficient degree of personal rehabilitation pursuant to Conn.
Gen. Stat. § 17a-112(j)(3)(B)(ii).
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In
re Christopher B (November 3, 2009)
Connecticut Appellate Court
November 3, 2009
Termination
of Parental Rights/Failure to Rehabilitate/Reasonable Efforts:...In
this termination of parental rights appeal, the appellate court
reiterated prior holdings that the trial court may consider
evidence pre-dating the filing of a neglect petition if that
evidence is relevant to an understand of the family dynamics
and the respondent's ability to safely parent a child. Here,
the appellate court rejected the respondent mother's claims
that the trial court gave undue weight to information regarding
DCF's prior involvement with her other children in considering
the adequacy of DCF's efforts to reunify her with Christopher
as well as whether the respondent had failed to rehabilitate
as a parent. The appellate court affirmed the trial court's
findings that the Department made reasonable efforts to reunify
her with her son and that she had failed to rehabilitate within
the meaning of the statute.
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In
re Tremaine C. (October 13, 2009)
Connecticut Appellate Court
October 13, 2009
Termination
of Parental Rights/Failure to Rehabilitate/Failure to Rehabilitate/Split
Decision:...In
a markedly split decision, the appellate court affirmed the
trial court's decision to terminate the respondent mother's
parental rights on failure to rehabilitate grounds. A primary
issue at trial was whether the mother's apparent progress with
substance abuse treatment and her current parenting of a newborn
child were sufficient to demonstrate that she could resume a
responsible parental role in young Tremaine's life. The trial
court held that the mother's ongoing struggles with dysfunctional
behavior, lack of employment, and transient living, combined
with her uneven visitation record, warranted a finding that
she had not constructively rehabilitated.
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In
re Tremaine (October 13, 2009)
Connecticut Appellate Court
October 13, 2009
Termination
of Parental Rights/Incarcerated Father/Due Process:...Respondent
father appealed judgment of the trial court terminating his
parental rights, on the ground that because he was incarcerated
for a portion of the trial and was not brought to the court
he was denied his constitutional right to be present at trial
and confront the witnesses against him. The appellate court
held that the although DCF belatedly discovered that the father
was incarcerated for a portion of the termination trial, the
steps taken to inform the court and permit the respondent's
subsequent participation in the trial were sufficient to address
any risk of erroneous deprivation of the father's rights.
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T.Y.,
K.Y. v. New York City Dept. of Educ. (October 9, 2009)
584
F.3d 412 (2d Cir. 2009)
Education: The crux of this Second Circuit special education
decision revolved around whether the Individuals with Disabilities
Improvement Act ("IDEA") requires Individualized Education Plans
("IEP") to identify a specific school location for an individual
student, or whether the IEP must merely describe the general
environment of an overall program for a student.
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In
re Jorden R. (October 6, 2009)
Connecticut Supreme Court
October 6, 2009
Termination
of Parental Rights:...In
this significant termination of parental rights appeal, not
only did the Supreme Court re-instate the trial court's decision
to terminate the respondent mother's parental rights, the Court
took the unusual step of vacating the opinion of the appellate
court, which held 1) that the state failed to demonstrate that
the mother could not benefit from reunification services, and
2) that the state could not show that the mother was unwilling
or unable to benefit from reunification services unless it had
already provided her reasonable assistive efforts. The Supreme
Court concluded that the first issue was moot on appeal and
therefore the appellate court lacked subject matter jurisdiction
to review the claim, and that the court's analysis of the reasonable
efforts requirement was contrary to the express language of
Conn. Gen. Stat. 17a-112(j).
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In
re Zion R. (September 1, 2009)
Connecticut Appellate Court
September 1, 2009
Termination
of Parental Rights/Rehabilitation/Best Interests:...This
termination of parental rights appeal underscores the sometimes
heartbreaking proposition that an even commendable personal
progress will not defeat a claim that a parent has failed to
achieve adequate "parental" rehabilitation. The case also highlights
the influence that court-appointed evaluators can have on the
findings of the trial court. In re Zion R involves a mother
with a long history of problems with substance abuse, domestic
violence, mental illness and incarceration who was in the midst
of a successful stay in a rigorous, long-term substance program
when her parental rights were terminated on "failure to rehabilitate"
grounds.
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In
re Nathan B. (August 18, 2009)
Connecticut Appellate Court
August 18, 2009
Termination of Parental Rights:
Judical Bias/Appearance of Impropriety:...In
this unusual and striking appeal of a termination of parental
rights decision, the sole issue was whether the trial judge's
continuing to preside at trial created an appearance of impropriety,
thereby requiring his recusal. The appellate court concluded
that it did, and reversed the judgment of the trial court.
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In
re S.D. (June 16, 2009)
Connecticut Appellate Court
May 26, 2009
Termination of Parental Rights:...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.
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In
re Justin F.
Conn. App. (2009)
Released June, 2009
Custody/Contempt/Visitation:...
Parents,
proceeding pro se, filed numerous appeals arising out of the
trial court's denial of their motion to revoke commitment, the
denial of their right to be heard on certain motions, and the
denial of their motion for contempt. The parents also claimed
on appeal that the "specific steps" orders violated their constitutional
rights and that the court improperly allowed the Department
to determine the nature and extent of family visitation. The
appellate court dealt quickly with the majority of the parents'
claims, determining that their arguments were either not preserved
or were inadequately briefed. Of note, however, is the appellate
court's treatment of the parents' claims regarding visitation.
- In
re Lyric H. (May 26, 2009)
Connecticut Appellate Court
May 26, 2009
Termination of Parental Rights:...In
this termination of parental rights appeal, the respondent mother
alleged that her daughter, Lyric, had a constitutional right to
conflict free legal representation and was deprived of that right
by her attorney. Finding the record inadequate to make a finding
on the conflict of interest claim, the appellate court declined
to decide whether the child had a constitutional right to effective,
conflict free representation.
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E.K.
v. Stamford Bd. of Educ., F. Supp. 3d (March 31, 2009)
United
States District Court, D. Conn.
Education: This case involved the defendant's, Stamford
Board of Education, renewed motion for an award of attorney's
fees and costs incurred in its defense against the plaintiffs,
a seventeen year old senior enrolled at Stamford High School
and his parents, "Mr. and Mrs. K."
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State
v. Juan L. (May 19, 2009)
Connecticut Supreme Court
Juvenile
Justice: ...The
sole issue decided by the Connecticut Supreme court in Juan
L. was the interpretation of whether Conn. Gen. Stat. § 54-56d,
which governs the commitment or release of criminal defendants
who are not competent to stand trial, applies in the Superior
Court for Juvenile Matters (juvenile court). The court answered
that question with a resounding yes - and agreed with the state's
argument on appeal and remanded the case back to the trial court
for a disposition hearing pursuant to Conn. Gen. Stat. § 54-56d(m).
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Hogan
v. Department of Children and Families (March 10, 2009)
Connecticut Supreme Court
March 10, 2009
Constitutionality of DCF's Abuse
and Neglect Central Registry:...A
former staff member at a state-licensed juvenile detention facility
challenged the validity of his placement on the child abuse
and neglect registry maintained by the Department of Children
and Families pursuant to C.G.S. §17a-101k on the grounds that
the factual record did not support the hearing officer's conclusions;
and that the registry statute itself was unconstitutionally
vague, overbroad, violated the separation of powers doctrine
and constituted a bill of attainder. The Supreme Court rejected
all of plaintiff's claims.
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In
re Xavier D. (March 31, 2009)
Connecticut Appellate Court
March 31, 2009
Termination of Parental Rights/Resjudicata:...The
appellate court rejected the mother's argument that the doctrine
of res judicata precluded further proceedings on a termination
petition by any trial court after another trial court had granted
the mother's motion for dismissal of the petition.
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In
re Anthony A. (February 17, 2009)
Connecticut Appellate Court
February 17, 2009
Termination of Parental Rights/Grandparent's
Motion to Transfer of Guardianship/Standing:...In
this consolidated appeal, the respondent mother appealed from
the trial court's judgment terminating her parental rights,
and the intervening maternal great-grandmother appealed from
the court's denial of the motion to revoke commitment and transfer
guardianship. The appellate court affirmed the judgment of the
trial court, finding that the decision to terminate parental
rights was not clearly erroneous and that the court's denial
of the motion for transfer of guardianship was not an abuse
of discretion.
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In
re Cheila R. (February 10, 2009)
Connecticut Appellate Court
February 10, 2009
Termination of Parental Rights.
Teenage Mother. Failure to Rehabilitate:...This
case involves an appeal from the trial court's order terminating
the parental rights of the respondent mother for failing to
rehabilitate. On appeal, the respondent mother alleged that
the court-ordered specific steps placed unreasonable demands
on her, causing her to feel overwhelmed, make poor decisions,
and appear as though she was abdicating her parental responsibility.
The appellate court affirmed the judgment of the trial court.
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In
re Deleon J. (February 10, 2009)
Connecticut Supreme Court
February 10, 2009
Reinstatement of Guardianship/Jurisdiction/Due Process:...
The
Supreme Court held that the trial court’s failure to provide
the petitioning parent with adequate notice and an opportunity
to be heard on the merits of her request for guardianship denied
her due process of law. The Court reversed the decision of the
trial court and remanded for further proceedings.
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In
re Melody L. (January 20, 2009)
Supreme Court
Termination
of Parental Rights, Failure to Rehabilitate, Reasonable Efforts,
Children's Right of Appeal, Heightened Scrutiny
:...
In this complex termination of parental rights appeal, the respondent
mother appealed the trial court's judgment of termination as
to her five children, alleging that the trial court (1) improperly
found that DCF had made reasonable efforts toward reunification;
(2) erroneously determined that she had failed to rehabilitate;
and (3) violated her rights under the state and federal constitution
by terminating her parental rights.
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In
re Janazia S. (January 13, 2009)
Connecticut Appellate Court
Termination
of Parental Rights, Statutory Construction: Failure to Rehabilitate
:...
This case involves an appeal from the trial court's order terminating
the parental rights of the respondent mother and father with
respect to their daughter, Janazia. On appeal, the respondent
father alleged that the trial court improperly denied his motion
to revoke commitment and transfer guardianship to the respondent
mother.
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In
re Francisco R. (December 9, 2008)
Connecticut Appellate Court
Neglect//Predictive
Neglect :...
This case is an appeal from the trial court's adjudication of
neglect as to Francisco R., an adjudication based on the doctrine
of predictive neglect. Respondent father claimed that the trial
court's adjudication of neglect was clearly erroneous because
there was no evidence that the child had been harmed, abused,
neglected, or uncared for prior to or on the date of the neglect
petition.
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In
re Justice V. (December 8, 2008)
Connecticut Appellate Court
Neglect//Evidence:
Terminating
parental rights on the ground of abandonment:...
The crux of the appeal was whether the trial court's failure
to issue specific following the neglect adjudication precluded
the trial court from granting termination of parental rights
on the ground of abandonment. Respondent mother also claimed
that the trial court's factual findings that TPR was warranted
were clearly erroneous.
-
In
re Tayler F. (October 28, 2008)
Connecticut Appellate Court
Neglect//Evidence:
Admissibility of children’s statements, preservation, testimony
regarding credibility:..In
this split decision, the respondent mother appealed the trial
court’s adjudication of neglect alleging the court improperly
admitted (1) testimony regarding whether the children should
testify in court; (2) hearsay evidence of statements by the
children, their father, and others; and (3) evidence of the
children’s credibility. The appellate court affirmed the judgment
of the trial court, agreeing that some evidence produced at
trial was inadmissible hearsay, but finding the admission of
such evidence harmless error in light of the overwhelming evidence
of child neglect.
-
P.
v. Newington Bd. of Educ., 546 F.3d 111 (2nd Cir. 2008)
Second
Circuit Court of Appeals
Education: The
Second Circuit Court of Appeals addressed the long standing
issue and adopted a standard for determining what constitutes
the least restrictive environment (LRE) under the statutory
obligations of the Individuals with Disabilities Education Act
(IDEA). The Court affirmed the granting of summary judgment
to the defendants Newington Board of Education holding that
the school complied with providing Plaintiff P. educational
services as mandated by the IDEA.
-
In
re Sarah S. (September 30, 2008)
Connecticut Appellate Court
Termination
of Parental Rights/Failure to Rehabilitate/Guardianship/Due
Process: In
this termination of parental rights appeal, the appellate court
affirmed the trial court’s termination decision, holding that
(1) the court properly denied the parent’s motion to transfer
guardianship to the paternal aunt; (2) there was ample evidence
to support a finding that the parents failed to rehabilitate;
and (3) the parents had not adequately briefed their claim that
the denial of a jury trial on the termination petition deprived
them of due process of law.
-
In
re Karl J. (September 2, 2008)
Connecticut Appellate Court
Abuse and Neglect/Guardianship/Motion to revoke: ...
This
case is an appeal from the judgment of the trial court awarding
custody and guardianship of Karl J. to the child's paternal
aunt and uncle. At issue was whether the court abused its discretion
in determining that it was in the best interests of the child
to remain in the care and custody of his paternal aunt and uncle.
Finding no abuse of discretion, the appellate court affirmed
the judgment of the trial court.
-
In
re Earl B (September 2008)
Connecticut Supreme Court
Juvenile Justice: ...In
this juvenile justice case, the Connecticut Supreme Court addressed
the question of whether a juvenile adjudicated as delinquent
and committed to the custody of the Department of Children and
Families pursuant to Conn. Gen. Stat. § 46b-140(j) is entitled
to a hearing pursuant to Conn. Gen. Stat. § 17a-15 to challenge
his continued placement at Connecticut Juvenile Training School
("CJTS"). The Supreme Court, in reversing the judgment of the
trial court, held that the department's decision to continue
placement at CJTS was reviewable in a treatment plan hearing
under § 17a-15.
-
In
re Devaun J. (August 26, 2008)
Connecticut Appellate Court
Termination
of Parental Rights/ Failure to Rehabilitate/ Open Adoption:
... In this termination of parental rights case, the appellate
court denied the mother's claim that the trial court improperly:
(1) failed to consider her statutory choice of a voluntary termination
of her parental rights and an open adoption; (2) concluded that
she failed to rehabilitate and that there was no ongoing parent-child
relationship; and (3) considered certain witnesses as expert
witnesses. The court also rejected the mother's claim that the
judgment of termination should be reversed because the postjudgment
report required by Conn. Gen. Stat. § 17a-112(o) was filed late.
-
In
re Forrest B. (August 19, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this case, the mother's appeal from a trial court's order of
temporary custody was dismissed on mootness grounds.
-
In
re Trevon G. (August 19, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this termination of parental rights case, the appellate court
denied the mother's claim that the trial court improperly concluded
that she failed to rehabilitate, that the department has failed
to make reasonable efforts to reunify her with her children
and that termination served the best interests of her children.
-
In
re Stephen M. (August 12, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this termination of parental rights appeal, the appellate court
reversed the trial court's dismissal of the state's termination
petition, holding that the trial court improperly re-considered
and rejected the underlying finding of neglect made in a previous
proceeding.
-
In
re Emerald C. (July 1, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this split decision, the appellate court affirmed the trial
court’s determination that the father’s inconsistent compliance
with court-ordered and DCF mandated expectations supported a
finding that he had failed to rehabilitate.
-
M.K.
ex rel. Mrs. K. v. Sergi. (May 12, 2008)
United States District Court, D. Conn.
Education: In
a case raising important disability discrimination issues, the
United States District Court in Connecticut granted summary
judgment in favor of the Commissioner of the State Department
of Education, the Department of Children and Families, the town
of Putnam Board of Education, and other individuals sued in
their official capacity.
-
In
re Coby C. (April 29, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
Respondent
mother appealed termination of parental rights decision contending
that the trial court’s finding that she failed to rehabilitate
and that termination was in the best interests of her child
was clearly erroneous."
-
Connecticut
v. Spellings. (April 28, 2008)
United States District Court, D. Conn.
Education: In
a significant decision, the United States District Court dismissed
the last remaining challenge brought by the state of Connecticut
to the No Child Left Behind Act (NCLB).
-
In
re Jorden R. (April 15, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this unusual case, the Appellate Court reversed a termination
of parental rights decision on the grounds that the trial court's
determination that the mother was unable or unwilling to benefit
from reunification services was clearly erroneous."
-
In
re Anthony A. (March, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..
In
this interesting neglect appeal, the respondent mother argued
that despite her significant psychiatric problems, her newborn
son should not have been adjudicated neglected because at the
time the neglect petition was filed the baby was living with
the maternal grandparents."
-
In
re Davonta V. (February 12, 2008)
Connecticut Supreme Court
Abuse and Neglect: ..The
fundamental question raised in this interesting appeal of a
termination of parental rights is whether it is ever in the
child's best interest to terminate his parental rights when
an adoptive family has not been secured and the child maintains
a good relationship with his extended biological family."
-
In
re Shanaira C. (February 12, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..How
much intervention should be allowed by an intervenor at a revocation
hearing? The answer, according to the Appellate Court in Shanaira
C., is not as much as the intervenor would have liked. The court
upheld the trials court's revocation of commitment, despite
a thoughtful and well-reasoned dissenting argument."
-
In
re Joseph L. (January 28, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..The
parents in this termination of parental rights appeal had a
long and significant history with DCF due to ongoing substance
abuse, domestic violence and ongoing child abuse and neglect
issues. The two children involved in this case were the mother's
ninth and ten children and the father's fourth and fifth. None
of the respondents' other children lived in the parents' care."
-
In
re T.K. (January 28, 2008)
Connecticut Appellate Court
Abuse and Neglect: ..In
this controversial case, the parents appealed the trial court's
decision that their child was neglected pursuant to a theory
of "predictive neglect." The parents' contended that absent
a history of problematic parenting or a demonstrated unwillingness
on the part of the parents to accept necessary services, the
doctrine of predictive neglect is inapplicable. The Appellate
court rejected the parents' argument and affirmed the decision
of the trial court.
-
In
re Leah S (December 18, 2007)
Connecticut Supreme Court
Abuse and Neglect: ...The
Supreme Court, reversing the judgment of the Appellate Court,
held that the Department of Children and Families could not
be held in contempt for violating the court-ordered Specific
Steps which mandated that the Department "ensure the [child's]
wellbeing" and "provide appropriate services." The Court determined,
ironically, that the Specific Steps were too vague to support
a finding of contempt.
-
In
re llyssa G. (December 18, 2007)
Connecticut Appellate Court
Abuse and Neglect: ..The
threshold for opening a default judgment in a termination of
parental rights case is a steep one which requires the satisfaction
of a two part test. Not only does the movant need to show that
(1) a good defense existed at the time the judgment was rendered,
but also (2) that the movant was prevented from making that
defense because of "mistake, accident, or other reasonable cause."
Unfortunately for the petitioning father in Ilyssa G., he was
unable meet either prong of the two-part test, and the appellate
court thus affirmed the termination of his parental rights in
this short case."
-
In
re Selena O (December 4, 2007)
Connecticut Appellate Court
Abuse and Neglect: ...In
this unusual case, the appellate court reversed the trial court's
denial of the state's TPR petition. The appellate court held
that the trial court's decision that the state failed to make
its "failure to rehabilitate" case was clearly erroneous. The
appellate court remanded for further proceedings."
-
In
re William D (November 13, 2007)
Connecticut Supreme Court
Juvenile Justice: ...In
this juvenile justice case, the Connecticut Supreme Court addressed
the question of whether a trial court may extend a delinquency
commitment when the "child" at issue has reached the age of
16, given that the definition of "child" in Conn. Gen. Stat.
46b-120 is defined as a 'person under sixteen' or a person over
16 who has a violated a court order issued subsequent to a delinquency
finding. In
this case neither definition applied to William D. The Supreme
Court held that for purposes of extending a person's commitment
pursuant to Conn. Gen. Stat. § 46b-141, it only matters what
age the person was at the time of the original commitment.
-
Bd.
of Educ. v.
Tom F. (October 10, 2007)
U.S. Supreme Court
Education: the Supreme Court affirmed, without opinion,
a Second Circuit court of appeals decision upholding the proposition
that parents need not "try out" a school district's placement
for an identified child if the placement is not appropriate
for the child.
-
In
re Anna Lee M (October 2, 2007)
Connecticut Appellate Court
Abuse and Neglect: ...In
this termination of parental rights appeal, the mother claimed
that the trial court erroneously relied on several pieces of
inadmissible evidence to support its finding that she "failed
to rehabilitate."
-
In
re Ryan R. (July 24, 2007)
Connecticut Appellate Court
Abuse and Neglect: ...In
this “failure to rehabilitate” TPR appeal, the court affirmed
the termination of the mother’s parental rights and concluded
that DCF had made reasonable efforts to reunify her with her
child.
-
In
re Francisco R. (May 8, 2007)
Connecticut Superior Court
Abuse and Neglect: ...Termination
of parental rights. Francisco was born February 3, 1995.
He may had been born with positive drug toxicology as his mother
abused drugs during pregnancy.
-
Winkelman
v. Parma City School Dist.
(May 21, 2007)
U.S. Supreme Court
Education: In a surprising reversal of a 6th Circuit
decision, the United States' Supreme Court held that parents
may bring a pro se court action regarding any procedural or
substantive claim arising under the Individuals with Disabilities
Education Act (IDEA.) The Court rejected the view of some circuit
courts that, under the statute, parents are merely "guardians"
of their children's right to an appropriate education, rather
than "real parties in interest".
-
M.K.
ex rel. Mrs. K v. Sergi. (Mar. 30, 2007)
United States District
Court, D. Conn.
Education: In a procedurally complicated case the parents
of a psychiatrically disabled teenager, and the prevailing party
in a due process hearing, sued, among other defendants, the
former Commissioner of the State Department of Education (SDOE)
for violations of IDEA.
-
.
(Mar. 30, 2007)
United States District
Court, D. Conn.
Education: This special education decision serves as
a warning to school districts regarding the consequences of
failing to include parents in the IEP process. In this case,
the parents sought reimbursement for private school placement
on the ground that the school district denied their daughter
an appropriate education and denied the parents the right to
participate meaningfully in the IEP process.
-
E.K.
v. Stamford Bd. Of Educ. (June 15, 2006)
United States District Court, D. Conn.
Education: In March 2005, a secondary school Planning
and Placement Team ("PPT") exited the plaintiff (E.K.), a student
in Stamford, Connecticut, from special education upon agreeing
he met the goals of his Individualized Education Plan ("IEP").
The plaintiff remained in regular education and neither his
parents nor he ever raised concerns regarding his need for special
education.
-
In
re Brianna C.
(December 26, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...The
Appellate Court affirmed an adjudication of neglect in the interesting
case of Brianna C., where the main reason for removal and foster
care placement was the father's paranoid schizophrenia resulting
in psychotic episodes.
-
In
re Christina M. (November 7, 2006)
Connecticut Supreme Court
Abuse and Neglect: ...In
this highly anticipated opinion, the Connecticut Supreme Court
held that parents have standing to assert claims that their
child was denied the right to effective counsel, but stopped
short of addressing the key issues raised in the appeal - namely
whether the conflict between a child's express wishes and her
attorney's position at trial merits constitutional review.
-
In
re Christian P. (October 24, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...tackles
the issue of whether parental rights may be terminated on a
ground that is not pleaded in the petition for termination.
The answer, not surprisingly, is no - and the object lesson
is that the state child welfare agency must plead the specific
grounds for termination in order for a court to consider those
grounds seeking termination of parental rights.
-
In
re Nasia B. (October 10, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...the
Appellate Court reversed the trial court's decision dismissing
the state's termination of parental rights petition for failure
to establish a prima facie case. The Court also reversed the
trial court's sua sponte decision to revoke DCF's custody of
the minor child and place the child at home under protective
supervision.
-
In
re Davonta V. (October 10, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...the
Appellate Court affirmed the trial court's decision to terminate
a mother's parental rights on the grounds that the mother failed
to achieve a reasonable degree of rehabilitation and termination
of parental rights was in the child's best interest.
-
In
re Rachel J. (October 3, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...In
a sad case that involved significant physical trauma and sexual
exploitation, the Appellate Court affirmed the termination of
a mother's parental rights in In re Rachel J.
-
In
re Nelmarie O. (September 19, 2006)
Connecticut Appellate Court
Abuse and Neglect: ...the
Appellate Court affirmed the trial court's decision to terminate
a mother's parental rights on the grounds that the mother failed
to provide her children with a safe home environment free of
violence and therefore she denied them the "care, guidance or
control necessary for [the children's] well-being."
-
(September 30, 2006)
U.S. District Court
Civil Rights, Education: In an interesting federal special
education decision, the United States District Court, District
of Connecticut, awarded plaintiff over $93,000 in attorney's
fees for a successful administrative hearing decision garnered
through a Due Process procedure.
-
Conn.
Office of Prot. and Advocacy for Persons with Disabilities v.
Hartford Bd. Of Educ.
(September 15, 2006)
The Second Circuit Court of Appeals
Education: The Second Circuit Court of Appeals affirmed
the District Court's judgment which entered a permanent injunction
against the Hartford Board of Education in the case of Protection
& Advocacy v. Hartford Bd. of Educ. This is the case where
the state office of Protection and Advocacy for Persons with
Disabilities (P&A) brought suit against the Hartford Board of
Educ. ("HBOE") requesting access to the HBOE's controversial
Hartford Transitional Learning Academy ("HTLA") to (1) observe
programs and speak with students and (2) give P&A a directory
of HTLA students and contact information for their parents/guardians
to investigate allegations of abuse and neglect at the school.
-
In
re Reginald H. (August 25, 2006)
Superior Court of Connecticut
Abuse and Neglect: This
is a decision on two so-called "Romance motions" filed in a
termination of parental rights case by petitioner, the Commissioner
of the Department of Children and Families ("DCF"), seeking
disclosure of certain of the mother's confidential medical and
substance abuse treatment information.
-
In
re Shaun B. (August 22, 2006)
Connecticut Appellate Court
Abuse and Neglect: In
a relatively straight forward termination of parental rights
case, the appellate court affirmed the termination of a mother's
parental rights where the trial court found the failure to rehabilitate
constituted the most significant barrier to reunification.
-
(June 26, 2006)
U.S. Supreme Court
Education: The omnipresent and always controversial issue
of attorneys' fees in special education found a path all the
way to the Supreme Court this past term. In Arlington Central
School Dist. v. Murphy, the plaintiffs sought fees for services
rendered by an educational consultant used during legal proceedings
held pursuant to the Individuals with Disabilities Education
Act ("IDEA"). Despite their status as the "prevailing party"
in the lengthy litigation, the Supreme Court overturned the
Second Circuit Court of Appeals by holding that 20 U.S.C. §
1415(i)(3)(B) does not authorizing prevailing parents to recover
expert fees.
-
In
re Anthony E. (July 11, 2006)
Connecticut Appellate Court
Family Law/Guardianship: This
case was an appeal from the judgment of the trial court modifying
a prior custody order and granting shared physical custody of
two minor children to the respondent mother. The issues on appeal
here were (1) did the trial court improperly find a material
change in the mother's circumstances and (2) did the trial court
abuse its discretion when it modified the original order of
custody without making a finding that doing so was in the children's
best interests.
-
In
re Leah S. (June 13, 2006)
Connecticut Appellate Court
Abuse and Neglect: In
an important decision that reverberates as an ongoing warning
to the state's child welfare agency, the Appellate Court upheld
a motion for contempt against the state Department of Children
and Families ("Department") for noncompliance the court orders
regarding the care of a child in the Department's care. The
essential element in the case was whether the Department's noncompliance
of court orders was willful, or merely negligent.
-
(May 18, 2006)
U.S. Supreme Court
Education, Legal Representation: The issue presented
on this appeal is whether the United States Supreme Court's
controversial holding regarding attorney's fees in Buckhannon
Bd. & Care Home, Inc. v. W. Va. Dept. of Health & Human Serv.,1
applies to a "prevailing defendant"? If so, was the Appellant
here a "prevailing defendant"? The Second Circuit Court of Appeals
held that a "prevailing party" under the federal fee-shifting
statute is one who has achieved a judicially sanctioned change
in the legal relationship among the parties, such as a judgment
on the merits or a court-ordered consent decree, applies to
"prevailing defendant" cases and further held that plaintiff
here was not a prevailing defendant under this standard.
-
Christopher
R. v. Comm'r. of Mental Retardation (April 4, 2006)
Connecticut Supreme Court
Mental Health : The
Connecticut Supreme Court weighed in on the issue of what criteria
are necessary for determining eligibility for services with
the state Department of Mental Retardation ("DMR").
-
In
re Stacey G. (March 21, 2006)
Connecticut Appellate Court
Abuse and Neglect: In
a short and straightforward case, the Appellate Court reversed
a trial court's denial of a father's motion to transfer guardianship
on evidentiary grounds, and because the trial court would not
grant a continuance to hear evidence from a forensic psychologist.
-
In
re Ashley. (February 1, 2006)
Connecticut Superior Court
Abuse and Neglect: trial
court denied the State's motion to compel a battered women's
shelter to disclose the mother's health records.
-
In
re Claudia F. (January 24, 2006)
Connecticut Appellate Court
Abuse and Neglect: The
question of mootness once again confronted the Appellate Court
in Claudia F. and the court answered in a resounding
fashion by determining that a respondent mother's voluntary
termination of her parental rights rendered an appeal of a neglect
adjudication moot.
-
Bruno
v. Greenwich Bd. Of Educ. (January 6, 2006)
United States District Court, D. Conn.
Education: Does
the failure to provide a copy of the notice of procedural safeguards
to an "adult" special education student constitute a per se
violation of the special education act, requiring an award of
compensatory educational services?
-
In
re Patricia C. (January 3, 2006)
Connecticut Appellate Court
Abuse and Neglect: Maintain
Commitment and Affirm a Permanency Plan
-
In
re Shaiesha O. (January 3, 2006)
Connecticut Appellate Court
Abuse and Neglect: Overturned
Termination of Parental Rights
-
In
re Nicholas R. (November 15, 2005)
Connecticut Appellate Court
Abuse and Neglect: In
a short but interesting case, the appellate court affirmed an
order of temporary custody ("OTC") obtained by the Department
of Children and Families ("Department") in September 2004. The
facts of the case are relatively straight forward - but the
language used by the appellate court regarding the nature of
consent, and the evidentiary consequences that result from forced
or coerced circumstances in child protection matters may resonate
in future cases.
-
(November 14, 2005)
U.S. Supreme Court
Special Education: In a decision that may have far reaching
implications for disabled students eligible for special education
services, the United States Supreme Court ruled that the burden
of proof in an administrative "due process" hearing challenging
the student's education plan is placed on the party seeking
relief, whether that party is the disabled child or the local
school district.
-
Scewczyk
v. Department of Social Services (September 20, 2005)
Connecticut Supreme Court
Medicaid: In an extremely important decision, the Connecticut
Supreme Court tackled the difficult issue of what exactly constitutes
an "emergency medical condition" under federal Medicaid law
and state social services policy.
-
In
re Christina M. (August 2, 2005)
Connecticut Appellate Court
Abuse and Neglect: Termination of Parental Rights:
This
case involves the termination of parental rights where neither
the children nor the parents want a separation, and where no
guardian ad litem was appointed despite the children's wishes
conflicting with their attorney's representation of their best
interest.
-
Carrubba
v. Moskowitz
(July 26, 2005)
Connecticut Supreme Court
Family Law, Legal Representation:
In a very important decision, the Connecticut Supreme Court
extended absolute, quasi-judicial immunity from subsequent
law suits against attorneys appointed by the courts to represent
children.
-
In
re Heather L. (June 21, 2005)
Connecticut Appellate Court
Abuse and Neglect: Termination of Parental Rights
-
In
re Brendan C. (June 14, 2005)
Connecticut Appellate Court
Abuse and Neglect: In this case, the parents of Brendan
C., an eight year old...
-
Szemerakis
v. Comm, Social Services (June 7, 2005)
Connecticut Supreme Court
Medicaid: In a narrow but disappointing decision, the
Connecticut Supreme Court...
-
A.R.
v. New York City Dept. of Educ. (May 10, 2005)
Federal District Court
Education: Do "winners" in administrative hearings governing
...
- In
re Krystal J. (April 05, 2005)
Connecticut Appellate Court
Abuse and Neglect: In a short yet convincing decision,
the appellate court upheld the denial of...
