termination of parental rights hearing in Connecticut

2002"In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in General Statutes [§ 17a-112 (k)]." (Internal quotation marks omitted.) In re Deana E. , 61 Conn. App. 185 , 190 , 763 A.2d 37 (2000).

2002"In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in General Statutes [§ 17a-112 (k)]." (Internal quotation marks omitted.) In re Deana E. , 61 Conn. App. 185 , 190 , 763 A.2d 37 (2000).

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2002III A. Mandatory Findings "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents' parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E ., 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2002III A. Mandatory Findings "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents' parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E ., 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2002III A. Mandatory Findings "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents' parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E ., 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2002I "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of . . . parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E. , 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2002III A. Mandatory Findings "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents' parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E ., 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2002I "In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of . . . parental rights is not in the best interests of the child." (Internal quotation marks omitted.) In re Ashley E. , 62 Conn. App. 307 , 315 , 771 A.2d 160 , cert. denied, 256 Conn. 910 , 772 A.2d 601 (2001).

2015Because of the sub- stantial interests involved, a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’’ (Citation omitted; footnote omitted; internal quotation marks omitted.) In re Alexander V., 223 Conn. 557, 569 , 613 A.2d 780 (1992).

2015Because of the sub- stantial interests involved, a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’’ (Citation omitted; footnote omitted; internal quotation marks omitted.) In re Alexander V., 223 Conn. 557, 569 , 613 A.2d 780 (1992).

2022In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.’’ (Internal quotation marks omitted.) In re Anthony H., 104 Conn. App. 744, 764 , 936 A.2d 638 (2007), cert. denied, 285 Conn. 920 , 943 A.2d 1100 (2008).

2022In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.’’ (Internal quotation marks omitted.) In re Anthony H., 104 Conn. App. 744, 764 , 936 A.2d 638 (2007), cert. denied, 285 Conn. 920 , 943 A.2d 1100 (2008).

2022In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.’’ (Internal quotation marks omitted.) In re Anthony H., 104 Conn. App. 744, 764 , 936 A.2d 638 (2007), cert. denied, 285 Conn. 920 , 943 A.2d 1100 (2008).

2022In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.’’ (Internal quotation marks omitted.) In re Anthony H., 104 Conn. App. 744, 764 , 936 A.2d 638 (2007), cert. denied, 285 Conn. 920 , 943 A.2d 1100 (2008).

2011“In the dispositional phase of a termination of parental rights hearing, the emphasis appropriately shifts from the conduct of the parent to the best interest of the child. . . . [T]he trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.” (Citations omitted; internal quotation marks omitted.) In re Janazia S., 112 Conn. App. 69, 97-98 , 961 A.2d 1036 (2009).

2011“In the dispositional phase of a termination of parental rights hearing, the emphasis appropriately shifts from the conduct of the parent to the best interest of the child. . . . [T]he trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child.” (Citations omitted; internal quotation marks omitted.) In re Janazia S., 112 Conn. App. 69, 97-98 , 961 A.2d 1036 (2009).

2001“In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents’ parental rights is not in the best interests of the child.” (Internal quotation marks omitted.) In re Denzel A., 53 Conn. App. 827, 831-33 , 733 A.2d 298 (1999).

2001“In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the parents’ parental rights is not in the best interests of the child.” (Internal quotation marks omitted.) In re Denzel A., 53 Conn. App. 827, 831-33 , 733 A.2d 298 (1999).

2001In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in § 17a-112 (d)." In re Tyscheicka H ., 61 Conn. App. 19 , 26 , ___ A.2d ___ (2000).

2001In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in § 17a-112 (d)." In re Tyscheicka H. , 61 Conn. App. 19 , 26 , ___ A.2d ___ (2000).

2017In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in ... § [17a-112 (k) ] ...." (Internal quotation marks omitted.) In re Alison M. , supra, 127 Conn.App. at 204 , 15 A.3d 194 .

2017In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in ... § [17a-112 (k) ] ...." (Internal quotation marks omitted.) In re Alison M. , supra, 127 Conn.App. at 204 , 15 A.3d 194 .

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Internal quotation marks omitted.) In re Joseph L., 105 Conn. App. 515, 529 , 939 A.2d 16 , cert. denied, 287 Conn. 902 , 947 A.2d 341 ,342 (2008). “[Once] the court finds that the petitioner has proven by clear and convincing evidence that one of the statutory grounds for termination of parental rights exists, it must then determine whether termination is in the best interests of the child. . . .

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Internal quotation marks omitted.) In re Joseph L., 105 Conn. App. 515, 529 , 939 A.2d 16 , cert. denied, 287 Conn. 902 , 947 A.2d 341 ,342 (2008). “[Once] the court finds that the petitioner has proven by clear and convincing evidence that one of the statutory grounds for termination of parental rights exists, it must then determine whether termination is in the best interests of the child. . . .

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Internal quotation marks omitted.) In re Joseph L., 105 Conn. App. 515, 529 , 939 A.2d 16 , cert. denied, 287 Conn. 902 , 947 A.2d 341 ,342 (2008). “[Once] the court finds that the petitioner has proven by clear and convincing evidence that one of the statutory grounds for termination of parental rights exists, it must then determine whether termination is in the best interests of the child. . . .

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Internal quotation marks omitted.) In re Joseph L., 105 Conn. App. 515, 529 , 939 A.2d 16 , cert. denied, 287 Conn. 902 , 947 A.2d 341 ,342 (2008). “[Once] the court finds that the petitioner has proven by clear and convincing evidence that one of the statutory grounds for termination of parental rights exists, it must then determine whether termination is in the best interests of the child. . . .

2006In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in ... § [17a-112 (k)] . . . .” (Internal quotation marks omitted.) In re Vanna A, 83 Conn. App. 17, 21-22 , 847 A.2d 1073 (2004).

2006In arriving at that decision, the court is mandated to consider and make written findings regarding seven factors delineated in ... § [17a-112 (k)] . . . .” (Internal quotation marks omitted.) In re Vanna A, 83 Conn. App. 17, 21-22 , 847 A.2d 1073 (2004).

2016In arriving at this decision, the court is mandated to consider and make written findings regarding [six] factors delineated in [§ 45a-717 (h) ]." (Internal quotation marks omitted.) In re Jaime S ., 120 Conn.App. 712 , 733-34, 994 A.2d 233 (2010), appeal dismissed, 300 Conn. 294 , 12 A.3d 566 (2011).

2016In arriving at this decision, the court is mandated to consider and make written findings regarding [six] factors delineated in [§ 45a-717 (h) ]." (Internal quotation marks omitted.) In re Jaime S ., 120 Conn.App. 712 , 733-34, 994 A.2d 233 (2010), appeal dismissed, 300 Conn. 294 , 12 A.3d 566 (2011).

2016In arriving at this decision, the court is mandated to consider and make written findings regarding [six] factors delineated in [§ 45a-717 (h) ]." (Internal quotation marks omitted.) In re Jaime S ., 120 Conn.App. 712 , 733-34, 994 A.2d 233 (2010), appeal dismissed, 300 Conn. 294 , 12 A.3d 566 (2011).

2016In arriving at this decision, the court is mandated to consider and make written findings regarding [six] factors delineated in [§ 45a-717 (h) ]." (Internal quotation marks omitted.) In re Jaime S ., 120 Conn.App. 712 , 733-34, 994 A.2d 233 (2010), appeal dismissed, 300 Conn. 294 , 12 A.3d 566 (2011).

2013In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child[ren].” (Internal quotation marks omitted.) In re Sarah O., 128 Conn. App. 323, 340 , 16 A.3d 1250 , cert. denied, 301 Conn. 928 , 22 A.3d 1275 (2011).

2013In the dispositional phase of a termination of parental rights hearing, the trial court must determine whether it is established by clear and convincing evidence that the continuation of the respondent’s parental rights is not in the best interest of the child[ren].” (Internal quotation marks omitted.) In re Sarah O., 128 Conn. App. 323, 340 , 16 A.3d 1250 , cert. denied, 301 Conn. 928 , 22 A.3d 1275 (2011).

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” 7 (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” 7 (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” 7 (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2007In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2010In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” 7 (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2007In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)].” (Citation omitted; internal quotation marks omitted.) In re Ryan R., 102 Conn. App. 608, 625-26 , 926 A.2d 690 , cert. denied, 284 Conn. 923 , 924, 933 A.2d 724 (2007).

2006In the dispositional phase of a termination of parental rights hearing, “the emphasis appropriately shifts from the conduct of the parent to the best interest of the child.” In re Romance M., 229 Conn. 345, 356-57 , 641 A.2d 378 (1994).

2006In the dispositional phase of a termination of parental rights hearing, “the emphasis appropriately shifts from the conduct of the parent to the best interest of the child.” In re Romance M., 229 Conn. 345, 356-57 , 641 A.2d 378 (1994).

2004In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)]. 6 On appeal, we will disturb the findings of the trial court in both the adjudication and disposition only if they are clearly erroneous.” In re Tabitha P., 39 Conn. App. 353, 361-62 , 664 A.2d 1168 (1995).

2004In arriving at this decision, the court is mandated to consider and make written findings regarding seven factors delineated in [§ 17a-112 (k)]. 6 On appeal, we will disturb the findings of the trial court in both the adjudication and disposition only if they are clearly erroneous.” In re Tabitha P., 39 Conn. App. 353, 361-62 , 664 A.2d 1168 (1995).

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2024The Supreme Court further has held, consistent with that statutory right, that ‘a parent in a termination of parental rights hearing has the right not only to counsel but to the effective assistance of counsel.’ ’’ (Footnote omit- ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567 , 143 A.3d 698 , cert. denied, 323 Conn. 913 , 150 A.3d 228 (2016). ‘‘In State v. Anonymous, 179 Conn. 155, 160 , 425 A.2d 939 (1979), our Supreme Court set forth the following standard for determining whether counsel has been ineffective in a termination proceeding: ‘The range of competence . . . requires not erro

2022We do not examine the record to determine whether the trier of fact could have reached a conclusion other than the one reached. . . . [Rather] every reasonable presump- tion is made in favor of the trial court’s ruling.’’ (Internal quotation marks omitted.) In re Malachi E., 188 Conn. App. 426, 443 , 204 A.3d 810 (2019). ‘‘In the dispositional phase of a termination of parental rights hearing, the emphasis appropriately shifts from the conduct of the parent to the best interest of the child. . . .

2022We do not examine the record to determine whether the trier of fact could have reached a conclusion other than the one reached. . . . [Rather] every reasonable presump- tion is made in favor of the trial court’s ruling.’’ (Internal quotation marks omitted.) In re Malachi E., 188 Conn. App. 426, 443 , 204 A.3d 810 (2019). ‘‘In the dispositional phase of a termination of parental rights hearing, the emphasis appropriately shifts from the conduct of the parent to the best interest of the child. . . .

2020Nevertheless, the petitioner urges this court to rely on In re Candace H., 259 Conn. 523 , 790 A.2d 1164 (2002), for ‘‘the inescapable conclusion that, once the [respondent] mother’s parental rights were terminated, there no longer was any practical relief the court could afford her regarding visitation because she no longer had a right to visit the child.’’ But In re Candace H. is factually and procedurally different from the present case and is much more analogous to the cases discussed previously, in which a pretermination motion for visita- tion is consolidated with the termination of pare

2020Nevertheless, the petitioner urges this court to rely on In re Candace H., 259 Conn. 523 , 790 A.2d 1164 (2002), for ‘‘the inescapable conclusion that, once the [respondent] mother’s parental rights were terminated, there no longer was any practical relief the court could afford her regarding visitation because she no longer had a right to visit the child.’’ But In re Candace H. is factually and procedurally different from the present case and is much more analogous to the cases discussed previously, in which a pretermination motion for visita- tion is consolidated with the termination of pare

2017In the dispositional phase, the trial court determines whether termination is in the best interests of the child." (Internal quotation marks omitted.) In re Paul O. , 141 Conn.App. 477 , 483, 62 A.3d 637 , cert. denied, 308 Conn. 933 , 64 A.3d 332 (2013) ; see also In re Victoria B. , 79 Conn.App. 245 , 261, 829 A.2d 855 (2003) (noting that, at the dispositional phase of a termination of parental rights hearing, "the emphasis appropriately shifts from the conduct of the parent to the best interest of the child" [internal quotation marks omitted] ).

2017In the dispositional phase, the trial court determines whether termination is in the best interests of the child." (Internal quotation marks omitted.) In re Paul O. , 141 Conn.App. 477 , 483, 62 A.3d 637 , cert. denied, 308 Conn. 933 , 64 A.3d 332 (2013) ; see also In re Victoria B. , 79 Conn.App. 245 , 261, 829 A.2d 855 (2003) (noting that, at the dispositional phase of a termination of parental rights hearing, "the emphasis appropriately shifts from the conduct of the parent to the best interest of the child" [internal quotation marks omitted] ).