In re Cameron W.

Syllabus

The respondent mother appealed to this court from the judgment of the trial court terminating her parental rights with respect to her minor child, C. She claimed that the trial court erroneously concluded, pursuant to the applicable statute (§17a-112 [j] [1]), that the Department of Chil- dren and Families made reasonable efforts to reunify her with C, and that she was unable or unwilling to benefit from reunification efforts. The trial court found, inter alia, that because of the mother's involvement with the criminal justice system and repeated return to substance abuse, she had not sufficiently rehabilitated to the extent that she could assume a responsible position in C's life in view of his age and needs or within a reasonable period of time. Held: 1. The trial court properly found that the petitioner, the Commissioner of Children and Families, proved by clear and convincing evidence that the respondent mother was unable or unwilling to benefit from reunification efforts: in making that determination, the court relied primarily on its subordinate findings that, prior to the date on which the petitioner filed the petition, the mother, who was incarcerated, did not plan on assuming the role of a parent to C or want to work toward reunification with C and stated a desire that C be adopted, and the mother's claim that, in analyzing the issue of reasonable efforts at reunification under § 17a- 112 (j), the court improperly failed to consider events that occurred after the adjudication date, which was the date on which the petitioner filed coterminous petitions for neglect and termination of parental rights, was unavailing, as it is a well settled principle that courts are required to consider only facts that occurred prior to the filing of a termination petition when making an assessment of whether reasonable efforts to reunify the parent with the child were made or whether there was sufficient evidence that a parent is unable or unwilling to benefit from reunificat