In re Juliany T.

Syllabus

The respondent father appealed from the judgment of the trial court terminat- ing his parental rights as to his minor child. He claimed, inter alia, that his counsel provided ineffective assistance that constituted reversible error, as the deficient performance was of such a magnitude that it created structural error pursuant to United States v. Cronic (466 U.S. 648). Held: This court declined to presume that the respondent father was prejudiced by his counsel's performance, as the presumption of prejudice standard set forth in Cronic does not extend to child protection matters. The respondent father could not prevail on his claim of ineffective assistance of counsel, as he inadequately briefed the issue of prejudice. This court rejected the respondent father's claim that he had a constitutional right to a hybrid habeas fact-finding proceeding in the trial court to more fully develop the record in support of his claim that he was denied the effective assistance of counsel, citing the precedent of the Supreme Court in In re Jonathan M. (255 Conn. 208) that there were other means of vindicating the right to the effective assistance of counsel through which an indigent parent may challenge a termination judgment, and this court declined to exercise its supervisory authority over the administration of justice to afford the father a right to such a fact-finding proceeding. Argued September 10, 2024—officially released February 3, 2025