In re Faith D.-A.

Syllabus

The petitioner, the Commissioner of Children and Families, sought to termi- nate the respondents' parental rights with respect to their minor child. Due to the COVID-19 pandemic, the trial on the termination petition was held remotely via Microsoft Teams. The respondent mother was represented by counsel and participated in the proceedings by telephone. The respondent father consented to termination. At the conclusion of the trial, the trial court rendered judgment terminating the respondents' parental rights. On the respondent mother's appeal, held that, pursuant to State v. Golding (213 Conn. 233), the record was inadequate to review the mother's claim that, by requiring her to participate in a virtual trial to terminate her parental rights without providing her with an electronic device that allowed her to appear before the court in the same manner as if she were on trial in a courtroom, she was denied due process of law and equal protection of the law under the fourteenth amendment to the United States constitution: although the parties agreed that the mother participated via telephone outside the proximity of her counsel, the record was silent as to whether the mother chose to turn her video off or whether she was unable to participate via video as a result of inadequate technology; moreover, other than one connectivity issue during the mother's canvass, there was no indication that she had diffi- culty hearing or participating at the trial, and the trial court repeated the canvass after being advised of the connectivity issue; furthermore, the mother did not ask for any technical assistance or accommodation during the trial; accordingly, the situation was analogous to that set forth in In re Vada V. (343 Conn. 730), in that the trial court was unable to assess any potential problems with the mother's ability to participate via video and had no occasion to consider alternative means for her to participate, to provide her with technology or Internet access, or to