The 1982 U.S. Supreme Court in Santosky v. Kramer, held that, as a matter of procedural due process, the federal constitution requires that the state prove the need to terminate the parent-child relationship by clear and convincing evidence and remanded the matter for findings under that standard, and it did not render insufficient the finding here, that the record was inadequate to review a father's unpreserved substantive due process claim that a least restrictive means test was required in a proceeding to terminate parental rights. The trial court terminated the parental rights of the respondent father, Julius B., pursuant to C.G.S. §17a-112(j) to his minor child for failure to achieve sufficient personal rehabilitation. The father appealed claiming that the termination of his parental rights violated his substantive due process rights guaranteed by the federal and state constitutions. He argued that depriving him of his fundamental liberty interest in the care, custody and control over his child required the court to find a compelling state interest and undertake a least restrictive means analysis in determining a proper permanency plan for the child. The Appellate Court affirmed the judgment. The respondent sought review of his unpreserved claim under the 1989 Connecticut Supreme Court decision in State v. Golding. He acknowledged that the record did not contain facts sufficient to determine whether there was a less restrictive means of securing a permanency plan in the best interest of the child but argued that the case should be remanded for further factual findings. Because the trial court did not make any specific findings regarding the placement alternatives newly raised on appeal, the record was inadequate to review the alleged claim of error and the claim failed under the first prong of Golding. The respondent argued that such a determination was insufficient to render judgment relying on Santosky. However, Santosky concerned a procedural due process issue which was litigated at trial while the respondent here is arguing a violation of his substantive due process rights which was not litigated at trial. The record in Santosky contained facts relating to the claim before the Supreme Court changed the burden of proof and did not require a second trial on remand, whereas the record here never contained facts that would support the respondent's claim.