In re Ricari B.

Syllabus

The respondent father appealed from the trial court's judgment terminating his parental rights with respect to his minor child. The father claimed that the court improperly determined that he was unable or unwilling to benefit from the reunification efforts of the Department of Children and Families. Held: The respondent father's appeal was not moot, despite the claim of the peti- tioner, the Commissioner of Children and Families, that the father had challenged only one of the two bases for the trial court's determination that the statutory (§ 17a-112 (j) (1)) requirements for the termination of parental rights had been satisfied, as the court did not make a finding by clear and convincing evidence that the department had made reasonable efforts to reunify the respondent with the child. This court concluded that the trial court's determination that the respondent father was unable or unwilling to benefit from the department's reunifica- tion efforts was supported by sufficient evidence, including evidence that the father had refused to communicate with the department for a five month period, that he had failed to benefit from counseling and substance abuse services, that he had tested positive for substances on numerous occasions, that he was inconsistent in complying with substance use tests, and that he had acted aggressively with probation staff, treatment providers, and department staff. Argued April 29—officially released May 20, 2026