· 5/17/2021

In re Skylar B.

Syllabus

The respondent father appealed to this court from the judgment of the trial court terminating his parental rights as to his minor child, S. On appeal, the father claimed that the court deprived him of his right to substantive due process because transfer of guardianship to S's relative foster par- ents would have been a less restrictive means than termination of his parental rights to achieve permanency. Held that this court declined to review the respondent father's unpreserved constitutional claim because the record was inadequate for review under the first prong of State v. Golding (213 Conn. 233): the father failed to file a motion to modify disposition and/or transfer guardianship to the relative foster parents, and neither the trial court, the petitioner, the Commissioner of Children and Families, nor S and the proposed guardians, whose lives would have been most affected by whether the father's parental rights remained intact, were on notice at the outset of the trial on the termination of parental rights petition that the father would be arguing for an alternative disposition; only a proper motion filed by a respondent serves to provide the requisite notice to all interested parties and the court of such an alternative disposition and the evidence that is particularly relevant to a disposition of a transfer of guardianship, as opposed to a termination of parental rights and adoption. Argued October 6, 2020—officially released May 17, 2021

Judges: Lavine; Elgo; Palmer

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