In Re: Dominico M.
In connection with a petition to terminate parental rights and under Connecticut General Statutes §17a-112(j), the Department of Children and Families was required to prove in the trial court, as stated in the 2011 Connecticut Supreme Court case of In re: Anvahnay S., "either that it has made reasonable efforts to reunify or, alternatively, that the parent is unwilling or unable to benefit from reunification efforts." The commissioner of children and families was granted temporary custody of D, L and N. Thereafter, the children were adjudicated neglected and committed to the commissioner's care and custody. The father of the children, Kenneth M., lived in North Carolina. The trial court granted the commissioner's petition to terminate the respondent father's parental rights to the three children. The respondent appealed from the judgment claiming that the court erred in finding that the department had made reasonable efforts to reunify him with his children and that he was unable or unwilling to benefit from reunification services. The Appellate Court affirmed the judgment. The respondent signed specific steps that required him to participate in counseling, undergo mental health and substance abuse evaluations, follow recommendations for treatment, undergo a domestic violence evaluation and cooperate with service providers. The record reflected that the respondent failed to follow through with recommended domestic violence services and refused to cooperate with a mental health or substance abuse evaluation. The trial court found credible evidence that the respondent repeatedly denied domestic violence in his relationship with the children's mother and refused to comply with recommended counseling. He refused to cooperate with a home study under the Interstate Compact on the Placement of Children. While he participated in some counseling services, he failed to disclose his history of substance abuse and domestic violence and was discharged. Such evidence sufficiently supported the court's reunification conclusions. The court did not err in terminating the respondent's parental rights.