In re Takie O.

Syllabus

The petitioner, the Commissioner of Children and Families, sought to termi- nate the respondents' parental rights with respect to their minor child. Due to the COVID-19 pandemic, the trial on the termination petition was held remotely via Microsoft Teams. The respondent father was represented by counsel and participated in the proceedings through audio and video means. The respondent mother consented to termina- tion. At the conclusion of the trial, the trial court rendered judgment terminating the respondents' parental rights. On the respondent father's appeal, held that the record was inadequate to review the father's claim that he was denied the right to confront the witnesses against him at the virtual trial in violation of the due process clause of the fourteenth amendment to the United States constitution: the father conceded that his claim was unpreserved because he did not raise it before the trial court; moreover, there was no factual record or factual finding on which this court could have based a determination of whether the father's right to confront the petitioner's witnesses was violated by the virtual format of the trial or whether the trial court correctly concluded that the government's interests were sufficiently great to warrant conducting the trial virtually; accordingly, the situation was analogous to those set forth in In re Annessa J. (343 Conn. 642), and In re Vada V. (343 Conn. 730), in which our Supreme Court recently determined that the respective respondents' claims failed to satisfy the first prong of the test for review of unpreserved constitutional claims set forth in State v. Golding (213 Conn. 233). Argued September 6—officially released October 4, 2022