In re Aligha R.-S.

Citation211 Conn.App. 39,271 A.3d 730 (Mem)
Decision Date31 January 2022
Docket NumberAC 44835
Parties IN RE ALIGHA R.-S. et al.
CourtAppellate Court of Connecticut

Paul A. Garlinghouse, New Haven, filed a brief for the appellant (respondent mother).

Nisa Khan, assistant attorney general, William Tong, attorney general, and Evan O'Roark, assistant attorney general, filed a brief for the appellee (petitioner).

Elgo, Moll and Bishop, Js.


The respondent mother appeals from the judgments of the trial court rendered in favor of the petitioner,1 the Commissioner of Children and Families, terminating her parental rights as to her minor children, Aligha R.-S., Alanah S., and Aarin R. On appeal, the respondent claims that the court improperly found that (1) the Department of Children and Families made reasonable efforts to reunify the family, (2) she failed to achieve a sufficient degree of personal rehabilitation pursuant to General Statutes § 17a-112 (j) (3) (B) (i), and (3) termination of her parental rights was in the best interests of the children. In addition, the respondent claims that the court improperly denied her motion to revoke commitment and that her trial counsel rendered ineffective assistance. We affirm the judgments of the trial court.

We note at the outset that the core findings that the respondent challenges are reviewed under deferential standards. See In re Terrance C. , 58 Conn. App. 389, 396, 755 A.2d 232 (2000) ("Before a termination of parental rights can be granted, the trial court must be convinced that the department has made reasonable efforts to reunite the child with his or her family. ... The trial court's ruling on [reasonable efforts] should not be disturbed on appeal unless, in light of the evidence in the entire record, it is clearly erroneous." (Citation omitted; internal quotation marks omitted.)); see also In re Avia M. , 188 Conn. App. 736, 738–39, 205 A.3d 764 (2019) ("Our standard of review on appeal is twofold. ... First, the court's ultimate conclusion of whether a parent has failed to rehabilitate is [reviewed under an evidentiary sufficiency standard], that is, whether the trial court could have reasonably concluded, upon the facts established and the reasonable inferences drawn therefrom, that the cumulative effect of the evidence was sufficient to justify its [ultimate conclusion]. ... When applying this standard, we construe the evidence in a manner most favorable to sustaining the judgment of the trial court. ... Second, the standard of review for the court's determination of the best interest of the child is clearly erroneous." (Citations omitted; internal quotation marks omitted.)); In re Patricia C. , 93 Conn. App. 25, 31, 887 A.2d 929 (standard of review for denial of motion to revoke commitment is clearly erroneous), cert. denied, 277 Conn. 931, 896 A.2d 101 (2006).

With respect to the respondent's ineffective assistance of counsel claim, our review is guided by the following principles: "In determining whether counsel has been ineffective in a termination proceeding, [this court has] enunciated the following standard: The range of competence ... requires not errorless counsel, and not counsel judged ineffective by hindsight, but counsel whose performance is reasonably competent, or within the range of competence displayed by lawyers with ordinary training and skill in [that particular area of the] law. ... The respondent must prove that [counsel's performance] fell below this standard of competency and also that the lack of competency contributed to the...

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