In re Janeleah I.

Syllabus

The respondent mother appealed from the trial court's judgment terminating her parental rights with respect to her minor child. The mother claimed, inter alia, that the court violated her right to procedural due process under the fourteenth amendment to the United States constitution by conducting the trial on the termination petition filed by the petitioner, the Commissioner of Children and Families, in her absence. Held: The trial court did not violate the respondent mother's right to procedural due process by conducting the termination of parental rights trial in her absence, this court having concluded that the trial court's action was not fundamentally unfair under the balancing test set forth in Mathews v. Eldridge (424 U.S. 319) and, thus, that the mother's unpreserved constitu- tional claim failed to satisfy the third requirement of State v. Golding (213 Conn. 233). This court determined that the trial court's failure to make the statutorily (§ 17a-112 (k) (7)) mandated written findings, by clear and convincing evi- dence, as to whether the unreasonable conduct of another person or the respondent mother's economic circumstances prevented the mother from maintaining a meaningful relationship with the child required reversal of the judgment with respect to the trial court's determination in the disposi- tional phase of the proceeding that it was in the child's best interest to terminate the mother's parental rights, as the criteria set forth in § 17a-112 (k) must be strictly complied with because the mother's fundamental right to parent the child was at stake. Argued May 27—officially released July 9, 2025 In accordance with the spirit and intent of General Statutes § 46b-142 (b) and Practice Book § 79a-12, the names of the parties involved in this appeal are not disclosed. The records and papers of this case shall be open for inspection only to persons having a proper interest therein and upon order of the court. Moreover, in accordance with federal law; see