A parent's right to effective assistance of counsel in a termination of parental rights proceeding is not rooted in the federal or state constitutions. With issues of substance abuse, domestic violence, physical neglect and criminal involvement of the father, the respondent mother's four children born between 2004 and 2008 were adjudicated neglected and committed to the care of the commissioner of children and families. The respondent mother agreed to specific steps for reunification but the trial court found her progress deteriorated. The court found, inter alia, that the respondent fled to Georgia to deliver a fifth child of the same father. Georgia authorities seized the infant, born testing positive for amphetamines, barbiturates and opiates.  She, thereafter, was arrested for prostitution and narcotics possession. The court granted the commissioner's petitions to terminate the parents' rights to the four children under C.G.S. §17a-112(j)(3) for failure to achieve sufficient personal rehabilitation. The respondent mother appealed claiming, first, that the court abused its discretion in denying her request for new trial counsel. The Appellate Court affirmed the judgment. The court granted the respondent's first court-appointed counsel's motion to withdraw due to a break down in the attorney-client relationship based on insufficient contact. Newly appointed counsel, Jean Park, filed a motion to withdraw citing similar reasons. The respondent indicated dissatisfaction with Park's performance. The Appellate Court found that the record amply supported the trial court's conclusion that there was no substantial reason to appoint new counsel because a new attorney would not have made a difference; the lack of communication was due to the respondent's conduct. The respondent's claim of ineffective assistance of counsel lacked merit. The trial court's findings of fact were not clearly erroneous and were sufficient to support the judgment. The respondent claimed her right to court-appointed appellate counsel under C.G.S. §45a-717 was denied. She argued that there should have been a brief to the court justifying the office of the chief public defender's determination that her appeal was without merit and judicial review of a determination that she should not receive the services of court-appointed counsel. However, no legal basis supported her contention that a statutory right to counsel in a termination of parental rights proceeding carries the same sixth amendment protections as a criminal proceeding.

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