In re Katia V.

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, who had been in foster care since birth. The trial court made the statutory (§ 17a-112 (j) (1)) findings that the Department of Children and Families had made reasonable efforts to reunify the mother with the child and that the mother was unable or unwilling to benefit from those efforts. The mother claimed that the department and the trial court violated her rights under the Americans with Disabilities Act of 1990 (ADA) (42 U.S.C. § 12101 et seq.) in determining that the department had made reasonable efforts at reunification, and that the court erred in denying her motions to bifurcate the adjudicatory and dispositional phases of the termination proceedings and to sequester the child's foster parents during trial. Held: 1. The respondent mother's challenge to the trial court's finding that the department had made reasonable efforts to reunify her with the child, which was based on her claim that the department and the court had violated her rights under the ADA, was moot; the mother failed to challenge the court's finding that she was unable or unwilling to benefit from the department's reunification efforts, and, because either finding is an independent basis to terminate parental rights, a review of her challenge to the finding that the department had made reasonable efforts to reunify her with the minor child could not have afforded her any practical relief. 2. The trial court did not abuse its discretion by denying the respondent mother's motion to bifurcate the proceedings: it was reasonable for the court to conclude that a unified trial was appropriate because two separate hearings would have undermined the court's interest in judicial economy, as well as the child's interest in the efficient resolution of the proceedings; moreover, there was nothing in the record to indicate that the court improperly considered d