clear and convincing standard in Connecticut

2010They were referred to services multiple times to encourage cooperation. [The respondent] has not been able to take full advantage of services, as he has been incarcerated for most of the current [department] involvement.” (Citation omitted.) Section 17a-112 (k) (2) requires the court to determine whether the department “has made reasonable efforts to reunite the family pursuant to the federal Adoption Assistance and Child Welfare Act of 1980, as amended . . . .” “The word reasonable is the linchpin on which the department’s efforts in a particular set of circumstances are to be adjudged, using

2010They were referred to services multiple times to encourage cooperation. [The respondent] has not been able to take full advantage of services, as he has been incarcerated for most of the current [department] involvement.” (Citation omitted.) Section 17a-112 (k) (2) requires the court to determine whether the department “has made reasonable efforts to reunite the family pursuant to the federal Adoption Assistance and Child Welfare Act of 1980, as amended . . . .” “The word reasonable is the linchpin on which the department’s efforts in a particular set of circumstances are to be adjudged, using

2001The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using the clear and convincing standard of proof . . . [R]easonable efforts means doing everything reasonable, not everything possible." (Citations omitted; internal quotation marks omitted.) In re Daniel C., 63 Conn. App. 339 , 360-61 , 776 A.2d 487 (2001).

2001The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using the clear and convincing standard of proof . . . [R]easonable efforts means doing everything reasonable, not everything possible." (Citations omitted; internal quotation marks omitted.) In re Daniel C., 63 Conn. App. 339 , 360-61 , 776 A.2d 487 (2001).

2002The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using the clear and convincing standard of proof. . . . [R]easonable efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objective standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case." (Citations omitted; internal quotation marks omitted.) In re Ebony H ., 68 Conn. App. 342 , 348-49 , 789 A.2d 1158 (2002).

2002The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using the clear and convincing standard of proof. . . . [R]easonable efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objective standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case." (Citations omitted; internal quotation marks omitted.) In re Ebony H ., 68 Conn. App. 342 , 348-49 , 789 A.2d 1158 (2002).

2001"General Statutes [Rev. 1999] § 17a-112 (c) provides in relevant part that `[t]he Superior Court . . . may grant a petition filed pursuant to this section if it finds by clear and convincing evidence (1) that the Department of Children and Families has made reasonable efforts to locate the parent and to reunify the child with the parent, unless the court finds in this proceeding that the parent is unable or unwilling to benefit from reunification efforts. . . .' `The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using

2001"General Statutes [Rev. 1999] § 17a-112 (c) provides in relevant part that `[t]he Superior Court . . . may grant a petition filed pursuant to this section if it finds by clear and convincing evidence (1) that the Department of Children and Families has made reasonable efforts to locate the parent and to reunify the child with the parent, unless the court finds in this proceeding that the parent is unable or unwilling to benefit from reunification efforts. . . .' `The word reasonable is the linchpin on which the department's efforts in a particular set of circumstances are to be adjudged, using

1998With respect to the first Miller prong, the clear and convincing standard is met only if “the evidence induces in the mind of the trier a reasonable belief that the facts asserted are highly probably true, that the probability that they are true or exist is substantially greater than the probability that they are false or do not exist.” (Emphasis in original; internal quotation marks omitted.) Id., 794 ; State v. Bonello, 210 Conn. 51, 66 , 554 A.2d 277 , cert. denied, 490 U.S. 1082 , 109 S. Ct. 2103 , 104 L.

1998With respect to the first Miller prong, the clear and convincing standard is met only if “the evidence induces in the mind of the trier a reasonable belief that the facts asserted are highly probably true, that the probability that they are true or exist is substantially greater than the probability that they are false or do not exist.” (Emphasis in original; internal quotation marks omitted.) Id., 794 ; State v. Bonello, 210 Conn. 51, 66 , 554 A.2d 277 , cert. denied, 490 U.S. 1082 , 109 S. Ct. 2103 , 104 L.

2000Furthermore, “reasonable efforts means doing everything reasonable, not everything possible . . . [but] such efforts should not make it impossible to attain reunification in a given case.” In re Eden F., 48 Conn. App. 290, 312 , 710 A.2d 771 (1998), rev’d on other grounds, 250 Conn. 674 , 741 A.2d 873 (1999).

2000Furthermore, “reasonable efforts means doing everything reasonable, not everything possible . . . [but] such efforts should not make it impossible to attain reunification in a given case.” In re Eden F., 48 Conn. App. 290, 312 , 710 A.2d 771 (1998), rev’d on other grounds, 250 Conn. 674 , 741 A.2d 873 (1999).

2024Zabaneh v. Dan Beard Associates, LLC, 105 Conn. App. 134, 140 , 937 A.2d 706 (applying plenary review to plaintiff’s claim that the [trial] court improperly required that it, rather than the defendant, bear the burden of proof regarding the existence of permission), cert. denied, 286 Conn. 916 , 945 A.2d 979 (2008); Wieselman v. Hoeniger, 103 Conn. App. 591 , 596-97, 930 A.2d 768 (applying plenary review to claim that although the court applied the clear and convincing standard of proof required to establish a fraudulent transfer, it did so to the wrong party), cert. denied, 284 Conn. 930 , 93

2024Zabaneh v. Dan Beard Associates, LLC, 105 Conn. App. 134, 140 , 937 A.2d 706 (applying plenary review to plaintiff’s claim that the [trial] court improperly required that it, rather than the defendant, bear the burden of proof regarding the existence of permission), cert. denied, 286 Conn. 916 , 945 A.2d 979 (2008); Wieselman v. Hoeniger, 103 Conn. App. 591 , 596-97, 930 A.2d 768 (applying plenary review to claim that although the court applied the clear and convincing standard of proof required to establish a fraudulent transfer, it did so to the wrong party), cert. denied, 284 Conn. 930 , 93

2024Zabaneh v. Dan Beard Associates, LLC, 105 Conn. App. 134, 140 , 937 A.2d 706 (applying plenary review to plaintiff’s claim that the [trial] court improperly required that it, rather than the defendant, bear the burden of proof regarding the existence of permission), cert. denied, 286 Conn. 916 , 945 A.2d 979 (2008); Wieselman v. Hoeniger, 103 Conn. App. 591 , 596-97, 930 A.2d 768 (applying plenary review to claim that although the court applied the clear and convincing standard of proof required to establish a fraudulent transfer, it did so to the wrong party), cert. denied, 284 Conn. 930 , 93

2024Zabaneh v. Dan Beard Associates, LLC, 105 Conn. App. 134, 140 , 937 A.2d 706 (applying plenary review to plaintiff’s claim that the [trial] court improperly required that it, rather than the defendant, bear the burden of proof regarding the existence of permission), cert. denied, 286 Conn. 916 , 945 A.2d 979 (2008); Wieselman v. Hoeniger, 103 Conn. App. 591 , 596-97, 930 A.2d 768 (applying plenary review to claim that although the court applied the clear and convincing standard of proof required to establish a fraudulent transfer, it did so to the wrong party), cert. denied, 284 Conn. 930 , 93

2015Although the standard of proof necessary for such a determination is clear and convincing evidence; see In re Christina M., 90 Conn. App. 565, 583 , 877 A.2d 941 (2005) (legisla- ture’s choice of proof by clear and convincing evidence in termination of parental rights proceedings is consistent with state and federal constitutional mandates), aff’d, 280 Conn. 474 , 908 A.2d 1073 (2006); the court’s use of this higher standard of proof could not prejudice the respondent. ‘‘The clear and convincing standard of proof is substantially greater than the usual civil standard of a preponderance of the

2015Although the standard of proof necessary for such a determination is clear and convincing evidence; see In re Christina M., 90 Conn. App. 565, 583 , 877 A.2d 941 (2005) (legisla- ture’s choice of proof by clear and convincing evidence in termination of parental rights proceedings is consistent with state and federal constitutional mandates), aff’d, 280 Conn. 474 , 908 A.2d 1073 (2006); the court’s use of this higher standard of proof could not prejudice the respondent. ‘‘The clear and convincing standard of proof is substantially greater than the usual civil standard of a preponderance of the

2022Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]easonable efforts means doing everything reasonable, not everything possible.’’ (Internal quotation marks omitted.) In re Jason R., 129 Conn. App. 746 , 767-68, 23 A.3d 18 (2011), aff’d, 306 Conn. 438 , 51 A.3d 334 (2012). ‘‘[I]n determining whether the department has made reasonable efforts to reunify a parent and a child or whether there is sufficient evidence that a parent is unable or unwilling to benefit from reunification efforts, t

2022Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]easonable efforts means doing everything reasonable, not everything possible.’’ (Internal quotation marks omitted.) In re Jason R., 129 Conn. App. 746 , 767-68, 23 A.3d 18 (2011), aff’d, 306 Conn. 438 , 51 A.3d 334 (2012). ‘‘[I]n determining whether the department has made reasonable efforts to reunify a parent and a child or whether there is sufficient evidence that a parent is unable or unwilling to benefit from reunification efforts, t

2020Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]eason- able efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objective standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case. . . . ‘‘This court has applied the general meaning of ‘reasonable’ and stated that [i]t is axiomatic that the law does not require a useless and futile act.’’ (Citation omitted;

2015Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]ea- sonable efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objec- tive standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case.’’ (Internal quotation marks omitted.) In re Kyara H., 147 Conn. App. 855 , 872–73, 83 A.3d 1264 , cert. denied, 311 Conn. 923 , 86 A.3d 468 (2014).

2020Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]eason- able efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objective standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case. . . . ‘‘This court has applied the general meaning of ‘reasonable’ and stated that [i]t is axiomatic that the law does not require a useless and futile act.’’ (Citation omitted;

2015Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]ea- sonable efforts means doing everything reasonable, not everything possible. . . . [R]easonableness is an objec- tive standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case.’’ (Internal quotation marks omitted.) In re Kyara H., 147 Conn. App. 855 , 872–73, 83 A.3d 1264 , cert. denied, 311 Conn. 923 , 86 A.3d 468 (2014).

2016Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn.... [R]easonable efforts means doing everything reasonable, not everything possible." (Citation omitted; internal quotation marks omitted.) In re Samantha C., 268 Conn. 614 , 632, 847 A.2d 883 (2004).

2016Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn.... [R]easonable efforts means doing everything reasonable, not everything possible." (Citation omitted; internal quotation marks omitted.) In re Samantha C., 268 Conn. 614 , 632, 847 A.2d 883 (2004).

2010Frederick Scholes Agency v. Mitchell, 191 Conn. 353, 358 , 464 A.2d 795 (1983); and as an intermediate standard; State v. Davis, [ 229 Conn. 285, 293 , 641 A.2d 370 (1994)]; between the ordinary civil standard of a preponderance of the evidence, or more probably than not, and the criminal *280 standard of proof beyond a reasonable doubt, this characterization does not mean that the clear and convincing standard is necessarily to be understood as lying equidistant between the two.

2010Frederick Scholes Agency v. Mitchell, 191 Conn. 353, 358 , 464 A.2d 795 (1983); and as an intermediate standard; State v. Davis, [ 229 Conn. 285, 293 , 641 A.2d 370 (1994)]; between the ordinary civil standard of a preponderance of the evidence, or more probably than not, and the criminal *280 standard of proof beyond a reasonable doubt, this characterization does not mean that the clear and convincing standard is necessarily to be understood as lying equidistant between the two.

2003Clear and convincing evidence must "induce in the mind of a trier a reasonable belief that the facts asserted are highly probably true, that the probability that they are true or exist is substantially greater than the probability that they are false or do not exist." State v. Bonello, 210 Conn. 51 at 66 , cert. den. 490 U.S. 1082 , 109 S.Ct. 2103 , 104 L.Ed.2d 664 (1989).

1998With respect to the first Miller prong, the clear and convincing standard is met only if “the evidence induces in the mind of the trier a reasonable belief that the facts asserted are highly probably true, that the probability that they are true or exist is substantially greater than the probability that they are false or do not exist.” (Emphasis in original; internal quotation marks omitted.) Id., 794 ; State v. Bonello, 210 Conn. 51, 66 , 554 A.2d 277 , cert. denied, 490 U.S. 1082 , 109 S. Ct. 2103 , 104 L.

2001"The word reasonable is the linchpin on which the department's [D.C.F.] efforts in a particular set of circumstances are to be adjudged using the clear and convincing standard of proof . . . [R]easonable efforts means doing everything reasonable, not everything possible." (Internal quotation marks omitted.) In Re Amanda A., 58 Conn. App. 451 , 455 . (2000).

2001Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [Reasonable efforts means doing everything reasonable, not everything possible.” (Internal quotation marks omitted.) Id., 455 , quoting In re Antonio M., 56 Conn. App. 534, 546 , 744 A.2d 915 (2000).

2001Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [Reasonable efforts means doing everything reasonable, not everything possible.” (Internal quotation marks omitted.) Id., 455 , quoting In re Antonio M., 56 Conn. App. 534, 546 , 744 A.2d 915 (2000).

2001Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [Reasonable efforts means doing everything reasonable, not everything possible.” (Internal quotation marks omitted.) Id., 455 , quoting In re Antonio M., 56 Conn. App. 534, 546 , 744 A.2d 915 (2000).

1999Neither the word “reasonable” nor the word “efforts” is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [Reasonable efforts means doing everything reasonable, not everything possible.’ In re Eden F., 48 Conn. App. 290, 311-12 , 710 A.2d 771 , cert. granted on other grounds, 245 Conn. 917 , 717 A.2d 234 (1998).

1999Neither the word “reasonable” nor the word “efforts” is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [Reasonable efforts means doing everything reasonable, not everything possible.’ In re Eden F., 48 Conn. App. 290, 311-12 , 710 A.2d 771 , cert. granted on other grounds, 245 Conn. 917 , 717 A.2d 234 (1998).

2025This court has consistently held that the [trial] court, [w]hen making its reasonable efforts determination . . . is limited to considering only those facts preceding the filing of the termination petition . . . .’’ (Internal quotation marks omitted.) In re Caiden B., 220 Conn. App. 326 , 348, 297 A.3d 1025 , cert. denied, 348 Conn. 904 , 301 A.3d 527 (2023). ‘‘The word reasonable is the linchpin on which the department’s efforts in a particular set of circumstances are to be adjudged, using the clear and convincing standard of proof.

2024Neither the word reasonable nor the word efforts is, however, defined by our legislature or by the federal act from which the requirement was drawn. . . . [R]easonableness is an objective standard . . . and whether reasonable efforts have been proven depends on the careful consideration of the circumstances of each individual case. . . . [R]easonable efforts means doing everything reasonable, not everything possible. . . . [O]ur courts are 0 Conn. App. 1 ,0 15 In re Jacqueline K. instructed to look to the totality of the facts and circumstances presented in each individual case in deciding whe