In Re Jocquyce.

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. In this case, the trial and appellate courts note the respondent mother’s progress with substance abuse treatment and acknowledge that the respondent mother was in recovery at the time the termination petitions were filed. Both courts also noted that the mother was successfully caring for an infant child at the time of the termination trial. However, the trial court, in granting the state’s petition to terminate the respondent’s rights, relied heavily on the report and testimony of the court-appointed evaluator, who concluded that the mother’s inability to fully acknowledge the impact of domestic violence on her family and her continued struggle with anger and parental responsibilities meant that the respondent mother would not likely be successful if reunified with her son. The appellate court held that there was sufficient evidence in the record to support the trial court’s finding.

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