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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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